Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?

Ensure all new developments are in keeping with each area and are not overwhelming in size to tower them and ruin heritage.

Protect these places from additional traffic brought on by development.

To consider the heritage there,
Look atCOL 7 and 20 and consider why they are heritage sites now. Do not destroy our history or the community assets for a few houses- our history is very important as you have already stated. Whole areas must be kept in tact, not split or moved to preserve this for our future generations.
You can best address this matter by leaving our heritage alone and support its upkeep.

The conservation areas of should be protected at all cost enough properties have been lost already the mill hall and civic suite are are under threat and should be protected .

Demolishing Mill Hall and building homes and a smaller hall in the conservation area along with homes around the Barrington's makes a mockery of your intention to protect central Rayleigh this should not happen.

Stambridge has a number of listed buildings which are alongside the main road. To help protect these buildings, a restriction on heavy lorries using Stambridge as a route would help. These heavy lorries pass the listed buildings very close and the vibration may damage the buildings.

There are several listed and older buildings in Stambridge which deserve to be protected, however, it concerns me that the amount of heavy lorries and traffic that travel through the village could cause lasting harm to these properties. There should be a better road network that means these heavier vehicles bypass the village

By protecting the districts conservation areas and example of this is to protect the civic suite and mill hall sites in Rayleigh

Consider ringfencing areas, buildings, trees etc to protect them. Rochford has a rich and colourful past, perhaps we can learn a lot from it, use it to promote to make the area more attractive to visitors?

Persimmon Homes would request that the Conservation Area Appraisals be updated as part of the emerging Local Plan process; these were last produced in 2007 so by the time the plan is adopted, these will be over 15 years old. The Local Authority are aware that settlements and areas change over time, and as such, it would assist greatly for these documents to be regularly reviewed.

Persimmon Homes are also concerned that our site at Western Road, Rayleigh (ref. CFS087) is marked poorly in the accompanying Site Appraisal Paper due to impacts on Built Heritage. This appears to have been assessed purely on the basis that there is a listed building – the Grade II listed Weir Farmhouse (List UID: 1322351) – but that this assessment has seemed to be have been undertaken purely as a mapping exercise and without any consideration to the sites relationship to this asset on the ground. The listed building is located a considerable distance from our site, and is screened from view not only by existing twentieth century development but also by considerable mature trees (which would be retained as part of any development proposals); therefore development of our site (ref. CFS087) would have no impacts on the setting of this listed building, as is fully confirmed within the Heritage Statement that accompanies these representations.

With reference to the Spatial Strategy Options, the Spatial Options Paper identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:

“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”

We would therefore recommend that all assessments of built heritage impacts be fully assessed by up to date evidence, noting that the Council’s Conservation Area Appraisals haven’t been updated since 2007 and therefore may not accurately reflect existing site conditions.

2 – The option to update the local list and protect and enhance assets through policy seems much simpler.

2 – The option to update the local list and protect and enhance assets through policy seems much simpler.

Q1.
Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
I would expect to see reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are needed to assess the long-term sustainability of any proposed sites. Without these I find it difficult to make any comments.
Evaluation of the impact of current development on Hullbridge
I cannot comment on the suitability of the sites in the plan without the Infrastructure Delivery and Funding Plan which I have been told is being undertaken at present. In my opinion it is premature to consult without these.
I would expect it to see reference to
i) the main Roads and the principal junctions and exit points to Hullbridge on Lower Road, Watery Lane and Hullbridge Road as well as the junction with Rawreth Lane.
ii) Consultation with the schools in Hullbridge, Hockley and Rayleigh to accurately asses capacity, too often there are no places in specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, currently the Riverside Medical Centre are not moving forward with expansion proposals due to high costs.
iv) Air Quality Management - too many parts of the District have poor CO2/CO readings
Any such Plan would need agreement with Rochford District Council, Essex County Council, and Southend Borough Council as they are all affected.
Q2.
Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included? [Please state reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for the hidden homeless (sofa surfers) or those on low incomes, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area. No provision for emergency housing.
Q3.
Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
Yes, as each settlement has its own characteristics and needs.
Q4.
Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
No comments.
Q5.
Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
Broadly yes. But it is important that the hierarchy is not changed through developments and cross boundary development must be carefully planned.
Q6.
Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. A single large urban development, possibly shared with Wickford could allow a more environmentally friendly development. A development that allows the infrastructure to be developed in advance of the housing.
Q7.
Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
Small development and windfall developments should be included in housing count.
Q8.
Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
Yes: Cultural and Accessibility.
Q9.
Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, houses, and businesses but also natural areas as well. The district needs good defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc. All building should be carbon neutral.
Q10.
Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
Yes. All coastal areas and areas of special interest, especially where there is a risk of flooding and harm to the environment need careful consideration.
The Ancient woodlands such as Kingley Woods, Hockley Woods and Rayleigh Grove Woods and all natural parks, not just the actual woodlands but also the surrounding areas and the proposed Regional Park to the West of Hullbridge.
Q11.
Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the district to supply low-carbon or renewable energy?
Yes.
New developments should be able to produce all energy requirements from zero carbon sources.
Q12.
Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at? [Please state reasoning].
Yes. The World is suffering a climate crisis, without higher standards we will not be able to reduce carbon sufficiently to avoid the crisis.
Q13.
How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
Solar and heat pumps in all new development as standard.
Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Q14.
Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the district, or should different principles apply to different areas? [Please state reasoning]
The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and again, SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15.
Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
Yes, but they must be kept to.
Q16.
a.
Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes.
b.
If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? [Please state reasoning]
You need different design guides as this district is both unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
c.
What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
You need to ensure that the character and heritage of the settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
Q17.
With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18.
With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
The district has a large number of houses, existing and approved that have four or five bedrooms. The number of homes available with two or three bedrooms is small, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. You must ensure that the “affordable“ properties are not all flats and that minimum or higher standards are met for gardens and recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living, residential or retirement homes. They may want a one or two bedroomed property, maybe one storey, or low-rise apartment that they own freehold.
We should safeguard the number of smaller bungalows available and make sure that the existing stock is preserved and a suitable number are provided in the housing mix. You need to consider that some residents may need residential care and you should be looking at ways to cope with the rising number of elderly and provide accommodation for them also.
Consideration should be given to the provision of house for life, bungalows and other potential buildings for downsizing families .
The plan makes no reference to social housing quotas.
The district desperately needs to meet the needs of the hidden homeless. People like the adult children on low wages who have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. You also need accessible properties for the disabled members of our community, where they are assisted in order to fulfil a normal as possible life. All these issues, and perhaps many more, need be addressed.
Q19.
Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled. Smaller, freehold properties for the older generation to enable them to downsize from large family homes. Emergency housing.
Q20.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and you should revisit the criteria for the traveller community to meet the legal requirements. Strong controls are needed to prevent illegal building work and to ensure the site populations do not exceed capacity.
Q21.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
See answer to Q20
Q22.
What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
See answer to Q20.
Q23.
With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
The council should stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. Consider how the plan can help those businesses wanting to expand. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes to train all ages get back into work or upskill. Developers should be encouraged to use local labour.
Q24.
With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
No. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. The plan should only formally protect sites the that have a future and a potential to expand or continue effectively.
Q25.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26.
Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Environmental services - woodland conservation and management. Improve manufacturing base and revisit the JAAP to make the airport Business Park a technological park.
Q27.
Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g., skills or connectivity?
Other forms of sustainable transport (Tram), gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. No new roads.
Q28.
With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
The airport brings little to the economy, It could be better used as an expanded technological park or for housing.
Q29.
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. You should conform to and improve existing policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings.
These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30.
Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31.
Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
On site. You can then assess in real time and sort out any issues you would not have known about off site.
Q32.
With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as well as providing new spaces and facilities. The sites should be well-maintained.
Q33.
Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes.
Q34.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
Q35.
With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37.
Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
Most of the District feels overcrowded; the road network is no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are often issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Q38.
With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39.
Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
All-weather facilities should be considered.
Q40.
Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42.
Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back. There are too few areas of accessible open space.
Q43.
With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan? [Please state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to those with impaired sight or mobility.
Q44.
Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing.
Q45.
Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46.
With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies.
Any plan should be reviewed frequently; at least every 4 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47.
Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
Yes.
Q48.
With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49.
Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size.
Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area. Retail parks, leisure areas and outlets are proving in many cases the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. I feel that some of the sites out forward in Rayleigh, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area.
Q51.
With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan? [Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention.
Q52.
Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a proper cycle network as part of the plan. A tram system. No new roads should be built.
Q53.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [Walking, cycling, rail, bus, road etc.]
Better links to the Chelmsford perhaps through a tram system, new roads must not be built. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Q54.
Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55.
Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a.
Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
No Comment
c.
Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called windfall development should be incorporated in the overall development targets thereby reducing large scale development.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e.
Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
Q57.
a.
Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
c.
Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Hockley Woods
Rayleigh Town Council. Spatial Plan Response 17 V 2.0 Published 13th September 2021
Q60.
a.
Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
No. This has been written by someone with no awareness of Hullbridge. I support the Parish Council Vision.
b.
With reference to Figure 48 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hullbridge?
The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2040 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.
Housing [market, affordable, specialist, traveller, other]
c.
Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
All of the areas lie within the green belt, and many will be within the projected 2040 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.
e.
Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.

At the moment, it appears that the Council are attempting to force development on to the existing residents of the district so that our once beautiful area makes us feel like we are hemmed in from all sides with no consideration for our needs or wellbeing.

The development on Hall Road is an example, where a loop hole was found to get away with not building the relevant facilities such as doctors and schools that were originally advertised.

The Developer gets rich from selling the properties, the council get rich from the additional revenue (which as a side note makes it disgusting that you are cutting your services) and the only people who lose out are the people who already live here.

The following points need to be considered:

- Suitable roads, doctors and school facilities must be incorporated into these developments without any loop holes that stop this from happening.

- Green belt land to be left well alone. We are a peninsula that should be encouraging wildlife, not killing it and scaring it away.

- buildings should fit in with the historical content of our area.

- affordable houses should be given to local people and not people shipped in from other areas.

1. Introduction
These representations are submitted by Wood Group UK Ltd (Wood) on behalf of Bloor Homes Ltd.
⚫ Section 2 provides a summary response to the Spatial Options consultation,
specifically in support the ‘Potential Cross-Boundary Opportunity’ east of Wickford,
explaining why the site should be part of whichever Strategy Option is taken forward
as it performs so well.
⚫ Section 3 sets out further detailed justification for a strategic land allocation to the
east of Wickford - centred on the release of sites CFS222 and CFS239 from the Green
Belt and improvements to remaining Green Belt in this area1
- in the context of
national Green Belt policy, sustainability, limited harm and the Council’s evidence base.
⚫ Section 4 explains the specific opportunities and benefits associated with a strategic
land allocation east of Wickford, supported by a concept masterplan and proposed
revision to the Green Belt boundary. This is intended to aid understanding of the
significant potential of this location.
⚫ Section 5 provides answers to the specific questions identified in the consultation
document.

2. Summary
A strategic site allocation to the east of Wickford has such significant credentials in sustainability
and Green Belt terms that it should be allocated as a strategic site whichever Strategy Option is
taken forward - the allocation could be central to Strategy Options 2, 3 or 4. Option 1 (urban
intensification) is unsound given that it does not meet the district’s housing needs and would not
constitute a positively prepared plan.
The size and status of Wickford as essentially a Tier 1 settlement equivalent to Rayleigh at the top
of Rochford’s settlement hierarchy means that this is where development should be focussed.
Wickford is a highly sustainable location for growth and development. It has a range of services,
two secondary schools, strategic employment, retail and a recently upgraded railway station
providing trains to London Liverpool Street. This is all within close proximity to land east of Wickford, which adjoins Wickford Business Park, lies on the A129 high frequency public transport
corridor and is just a 15-minute bus/cycle journey to the railway station and town centre.
In Green Belt terms the ‘exceptional circumstances’ for reviewing boundaries required by NPPF140
are evidenced and justified by the lack of available land outside the Green Belt to meet the district’s
needs through to 2040. When reviewing Green Belt boundaries, the promotion of sustainable
patterns of development and use of previously developed land or sites well-served by public
transport are policy requirements (NPPF142) which the site supports given the sustainability
credentials outlined above. The extent of land controlled by Bloor in this location also provides
the opportunity for compensatory improvements to the remaining Green Belt, through the
provision of new/enhanced sports pitches, biodiversity net-gain and improvements to
walking/cycle links (also NPPF142).
Land east of Wickford is well-related to the urban edge, is visually well-contained, already contains
urbanising influences and has the long term robust boundary of the A130. The presence of the
A130 as such a strong recognisable physical barrier - central to defining Green Belt boundaries
through plan-making under NPPF143(f) - is a particular advantage that other strategic Green Belt
locations in Rochford district do not have (for example, in contrast, there is no such significant and
defensible barrier for development sites centred on Strategy Option 3b, north of Southend).
Release of land east of Wickford will therefore not result in urban sprawl, nor lead to neighbouring
towns merging or encroachment into the countryside. In Green Belt terms land east of Wickford is
a unique opportunity and the best performing strategic location for Green Belt land release,
resulting in the least harm.
From a landscape and heritage perspective it also one of the best performing strategic locations
assessed as part of the Spatial Options consultation (again, in contrast, Strategy Option 3b is in
proximity to designated heritage assets and in an area with low landscape capacity to
accommodate new development). It also an area of lower landscape sensitivity when compared
with other options.
As illustrated on the accompanying plans (Appendix A), a strategic site allocation east of Wickford
can deliver around 1,500 new homes and employment at a scale which supports the delivery of
new community infrastructure, including a primary school and new local centre (convenience retail
and other community facilities). An allocation here would reduce the pressure on other
communities in Rochford district.
In terms of delivery, the land is all under the single control of Bloor Homes, a 5* housebuilder
committed to working with Rochford District Council, the local community and key stakeholders to
realise the opportunities presented by this important opportunity.

3. Justification for a strategic land allocation /
cross boundary opportunity east of Wickford
3.1 Green Belt
NPPF Green Belt Policy
Exceptional circumstances (NPPF140)
The case for exceptional circumstances for Green Belt land release in Rochford – as required by
NPPF140 - is established under Strategy Options 2 and 3. As recognised on page 29 of the Spatial
Options, Strategy Option 1 (urban intensification), predicated on no Green Belt land release, will
not meet Rochford’s growth needs, and is therefore unlikely to be considered sound, being not
positively prepared. Green Belt land is needed. The question is where the best locations are to do
so whilst limiting the overall harm to the Green Belt and with respect to the requirements of
NPPF142 and NPPF143 in particular.
Promoting sustainable patterns of development and giving first consideration to land which has
been previously-developed ‘and/or’ is well-served by public transport (NPPF142)
Wickford is rightly recognised as equivalent to a Tier 1 settlement2
– i.e. the top of the settlement
hierarchy alongside Rayleigh. It has two secondary schools, strategic employment and retail, with
Wickford railway station - recently subject to a £4m package of improvements – providing trains
into London Liverpool Street.
Land east of Wickford is highly sustainable, as supported by the Council’s evidence base, including
the Complete Communities Topic Paper. As shown on Figure 4 of this topic paper the site adjoins
frequent public transport (more than 4 services per hour), with bus stops to the north west
(Southend Road roundabout3
), east (A129/Old London Road) and west (Hodgson Way). As part of
a strategic site allocation there is the potential to route a bus into the site and enhance
accessibility.
As supported by the Site Appraisal Paper all key facilities are nearby, including secondary school
(Beachamps High), local shops and Post Office (centred around the junction of Southend
Road/Fanton Walk/Bruce Grove), healthcare (Shotgate Surgery), jobs and employment (at
Dollymans Farm, Wickford Business Park & Fanton Hall Farm). Furthermore, the site is well-located
in proximity to extensive areas of open space, including sports pitches at The Warren, Rayleigh FC
Boys & Girls, Chichester Ground Football Pitches and Shotgate Park (with respect to the Site
Appraisal Paper, the site should at least score ‘4’ given proximity within 400-800 metres). Land
east of Wickford is just a 15-minute bus/cycle journey from the railway station and the town centre.

Promoting sustainable patterns of development in NPPF Green Belt terms therefore means
directing a significant share of new growth and development towards Wickford, whichever Strategy
Option of 2, 3 or 4 is pursued.
The site is already part brownfield and part developed with clear urbanising influences - as
acknowledged in the Site Appraisal Paper - encompassing one of the district’s twelve ‘informal
employment areas’ (Economy & Skills Topic Paper) as well as an existing dwelling and curtilage at
Dollymans Farm.
A particular benefit in terms of sustainable patterns of development is the ability to provide a scale
of development which supports additional infrastructure and investment, with the 1,500 homes at a
level which sustains provision of a new primary school, as well as supporting facilities including a
local centre, which alongside existing and enhanced public transport all helps to create a truly
‘walkable’ neighbourhood. The ability for strategic allocations to deliver infrastructure
improvements is identified in the Spatial Options Document, supporting Strategy Options Topic
Paper and the Interim Integrated Impact Assessment IIA4
. This will also be a sustainability benefit to
the existing area – including users of Wickford Business Park and neighbouring residential areas.
This would support the intentions of Strategy Options 2, 3 and 4 whereby the ability to fund and
deliver new infrastructure is identified as a clear opportunity.
Delivering compensatory improvements to the environmental quality and accessibility of the
remaining Green Belt land (NPPF142)
Compensatory improvements to the environmental quality and accessibility of the remaining Green
Belt - another key objective of NPPF142 - could also be secured given the extent of land within
Bloor Homes’ control (e.g. around CFS223, 226, 227, 230 & 238). Improvements could include a
combination of enhanced green infrastructure connectivity, new recreational routes for walking and
cycling and additional playing fields/sports provision. This would also align with NPPG002 (Green
Belt - Reference ID: 64-002-20190722) in terms of the range of compensatory improvements. By
tying such improvements in with the allocation and future planning permission, this would also be
deliverable in the context of NPPG003 (Reference ID: 64-003-20190722) and can be secured via the
S106 process.

Defining a clear Green Belt boundary (NPPF143(f))
The A130 is a significant clear physical feature and long term permanent boundary to the east of
Wickford which would form a logical defensible boundary which is capable of enduring beyond the
plan period. In this regard land east of Wickford is a unique opportunity – with no other strategic
locations having such a significant and robust Green Belt boundary, in combination with
accessibility, sustainability and suitability (being of lower environmental value).
The Council’s Green Belt Study (Assessment Area AA01 / Sites 222, 239, 238 & 223)
Against the fundamental purpose of the Green Belt – to prevent urban sprawl (NPPF137) – the
Green Belt Study rightly recognises that the area makes a weak contribution. Surprisingly it then
identifies a ‘High’ harm impact score which then follows through into the Site Appraisal Paper.

This appears predicated on the conclusion that the area makes a ‘strong contribution’ to
preventing encroachment on the countryside. However, the assessment is flawed because it fails to
reflect the existing urbanising influences in the area, incorrectly stating that the area is
undeveloped. The presence and extent of ‘urbanising land uses and features that could diminish
openness or compromise the rural character of the countryside’ are identified as key factors in the
Green Belt Study’s own methodology (2.46, 2.477, 2.50 and 2.53) but then disregarded in the
assessment of Parcel 1/AA01. Examples of the urbanising features on the site are illustrated on the
photographs presented at Figure 2. Urbanising influences include the employment areas at
Dollymans Farm (note: non-agricultural uses), and residential use at Dollymans Farm itself, as well
Fanton Hall employment area to the south east. The presence of the A129 and A130, pylons,
employment distribution infrastructure and railway line are also urbanising influences.
Furthermore, the assessment of encroachment and wider performance of the land in this area in
terms of Green Belt purposes then fails to reflect the role of strong physical boundaries, i.e. the
A130 in this case. The dictionary definition of encroachment concerns a gradual advance beyond
usual or ‘acceptable limits’ – the acceptable limit in this case being the A130. This should be a
fundamental consideration as part of the assessment and at present is a significant omission in the
study’s methodology and in the appraisal of Parcel 1/AA01. The assessment should be revised to
conclude a weak contribution to this Green Belt purpose.
In reality, and as explained earlier in this section this is a unique and strongly performing Green
Belt site because it is so well-related to the existing urban edge, already contains urbanising
influences, is visually well-contained and has such a strong boundary in the A130 that other
strategic development locations do not have. It is the best option with the least level of harm to
the Green Belt particularly with regard to the fundamental policy aim of the NPPF in preventing
urban sprawl.
Revised scoring for Parcel 01 (from the Stage 1 Assessment) and Parcel AA01 (from the Stage 2
Assessment) is therefore presented in Figure 3. It is concluded that the overall contribution to
Green Belt purposes is weak and the harm of release reduces to low-moderate. This should then
be coupled with the site’s sustainable development credentials.

Wider local plan evidence base: Site Appraisal Paper – Land East of Wickford
The Site Appraisal Paper identifies all land within Bloor Home’s control in this location as
deliverable within 5-years subject to policy, encompassing sites CFS222, CFS239, CFS238, CFS223
and CFS226. The Site Appraisal Paper shows how well-located the area is in landscape terms, lying
outside of the more sensitive landscapes in the district. Informed by the findings of the Landscape
Character, Sensitivity and Capacity Study identifies land east of Wickford as lying within a ‘LowMedium’ landscape sensitivity and ‘Medium-High’ landscape capacity to accommodate
development. The main development sites comprising CFS222 and CFS239 are also unaffected by
designated heritage assets, unlike other strategic development areas assessed in the District.
These sites all perform well in terms of accessibility given proximity to high frequency public transport on the A129 and access to facilities and services. However, there is an inaccuracy in the
scoring with respect to access to open spaces. This does not reflect the latest position on the ground, whereby the sites are very well-located in proximity to extensive areas of open space,
including sports pitches at The Warren, Rayleigh FC Boys & Girls, Chichester Ground Football
Pitches as well as Shotgate Park. The scoring for CFS222 and CFS239 should be increased from ‘1’
to ‘4’ given the extent of open space provision already within 400-800m.
In terms of access to public transport, whilst accessibility to high frequency bus routes is
recognised, the scoring for CFS222 does not yet reflect the ability to deliver
enhancements/improvements as a central part of any development scheme. In reality CFS239 –
which scores well with a ‘4’ given that it abuts the A129 and is within 400 metres of bus stops at
Southend Road roundabout – would form part of the single comprehensive allocation which aligns
with the masterplan enclosed at Appendix A. The masterplan reflects the ability for a bus to route
in and out of the scheme in order that new homes would be within 400m, so this could easily be dealt with as part of the allocation and consenting process, in which case CFS222 would also score
4.
Figure 4 presents the revised scoring for sites CFS222 and CFS239 under Bloor’s control on land east of Wickford which are to form the main area for Green Belt land release presented in section 4.
The land clearly outperforms other locations with respect to Green Belt, landscape, accessibility,
ecology and heritage.

4. Strategic land allocation - concept masterplan,
potential & opportunities
As summarised in section 2 and justified in section 3, land east of Wickford is the best location for a strategic land allocation, and should play an important role under Strategy Options 2, 3 and 4. In Green Belt terms, Wickford’s status akin to a Tier 1 settlement, accessibility to high frequency
public transport, services and facilities – and ability to deliver new community infrastructure – is
entirely consistent with promoting the sustainable patterns of development envisaged by NPPF142.
The A130 is a strong and longer term defensible Green Belt boundary unique to this location, helping limit sprawl and encroachment. Alongside the area’s relationship with the existing urban edge, visual containment and existing urbanising influences it is the best performing location for
Green Belt land release with the least harm to the overall role and function of the Green Belt in Rochford district.
In landscape and heritage terms this area would also result in the least harm when compared with other strategic options. It provides the opportunity for the Council to deliver growth in a location which minimises impacts on existing communities and environmental assets.
Appendix A provides a draft concept masterplan, with Appendix B providing a context plan and proposed revision to the Green Belt boundary in this location.
The draft concept masterplan is based on the following key features and benefits.
⚫ Around 1,500 homes, a mix of market and affordable in response to local needs, on a net residential area of around 40ha.
⚫ 2ha of land for a new 2FE primary school, supporting the Spatial Options opportunity to deliver growth at a scale which provides and sustains new infrastructure.
⚫ A new local centre, located next to the new school site, providing convenience retail
and other community uses.
⚫ A robust, long-term and defensible Green Belt boundary, capable of enduring beyond the plan period and supporting the sustainable patterns of development envisaged by NPPF142(f) Green Belt policy. The A130 and railway line provides a clear boundary using an existing physical feature that is readily recognisable and likely to be permanent, entirely consistent with NPPF132(f). Appendix B sets out the proposed Green Belt boundary revision.
⚫ New and enhanced playing pitches as a ‘hub’ for sports and recreation. The Council’s Playing Pitch Assessment and Action Plan identifies the opportunity to provide greater security of tenure for sports provision in this location – including at The Warren (CFS226) which is land under Bloor’s control. Further pitches could be provided west of the Warren/A130 or land to the east which is also within Bloor’s control. This would utilise existing bridleways all of which would link sports provision with the new homes, across the existing Pegasus crossing on the A129, with access off the A129.

Alongside the bridleways and existing crossing, the scheme would promote the use of public transport through the ability to route a bus into the site to secure a 400m walkable catchment and could provide ped/cycle links to the west through to Wickford.
⚫ Visual containment can be maximised by retaining key landscape features and enhancing structural planting alongside the site’s northern and eastern boundaries, complemented by the provision of sustainable drainage and wildlife habitats to deliver net biodiversity gain all on-site. 50% of the site would comprise green uses.
⚫ Access would be via a new roundabout on the A129, providing a tree-lined avenue
into the neighbourhood, with a potential secondary access located to the east (refer to
the masterplan in Appendix A for details).

5. Response to specific questions
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
For the reasons explained in section 2, the cross-boundary opportunity east of Wickford has such
significant and unique credentials in sustainability, Green Belt and deliverability terms that it has a
role to play in delivering all Strategy Options 2, 3 and 4.
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
Standards for new developments relating to both energy supply and energy efficiency standards should be left to national building regulations (e.g. linked to the Future Homes Standard or similar
initiatives in the future).
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford could clearly support
the opportunity for new green infrastructure, including a new hub for sports provision in this
location (improving both the quality and quantity of sports pitches), improvements to GI
connectivity (e.g. upgrading existing bridleways), biodiversity net gains and further strategic
landscaping, particularly associated with the establishment of a robust and defensible Green Belt
boundary to the east of Wickford / west of the A130. This package of measures would also support
the environmental quality and accessibility of remaining Green Belt land, as set out in NPPF142.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to
deliver new or improved community infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford can deliver growth at
a scale – 1,500 homes plus employment - which provides and sustains new community facilities,
including land for a 2FE primary school, new local centre (which provides convenience retail and
other community provision), extensive green infrastructure as well as new and enhanced sports
provision. Further details are provided in sections 3 and 4 of these representations.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help
deliver improvements to open space or sport facility accessibility or provision?
Bringing forward a strategic land allocation east of Wickford – under Strategy Options 2, 3 or 4 –
would support improvements to open space and sports provision. There are opportunities to deliver additional pitches as well as greater security of tenure, for example, on retained Green Belt
land centred on sites CFS223 and CFS226, all on land which Bloor Homes controls and would tie in
with a new strategic land allocation. The opportunity to provide greater security of tenure at The
Warren in particular (CFS223) is identified in the Playing Pitch Assessment and Action Plan. Further
details are provided in sections 3 and 4 of these representations, with the opportunity to provided
new pitches identified on the concept masterplan presented in Appendix A (6-7ha of
new/enhanced pitch provision complemented by extensive green infrastructure and biodiversity
net gains).
Q43. With reference to the options listed in this section, or your own options, how do you feel we
can best address heritage issues through the plan?
The potential for impacts on the significance of heritage assets and their setting is a key constraint
to consider through plan-making and subsequent decision-taking on planning applications. The
Council should look therefore towards options with no/limited heritage constraints, as is the case
for land east of Wickford, recognised in both the Site Appraisal Paper and IIA.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
Growth should be directed to the most sustainable locations already well-served by high frequency
public transport, services and facilities, and where there is the opportunity to deliver a scale of development to sustain new services and facilities to deliver truly walkable neighbourhoods.
Promoting sustainable patterns of development is central to the review and release of Green Belt land and where land east of Wickford performs particularly well. Wickford is equivalent to a Tier 1
settlement, has rail access into London Liverpool Street, with the opportunity that Bloor has identified just a 15-minute bus/cycle ride to the station and lying on a high frequency public transport corridor (recognised in the Connecting Communities Topic Paper). Land east of Wickford
is already identified as having a positive contribution to sustainable transport in the IIA. Further detail on transport and sustainability for the cross-boundary opportunity east of Wickford is provided in sections 2, 3 and 4 of these representations.

Having reviewed the Strategy Options presented, Option 3b appears less suitable in transport terms for the following reasons.
⚫ A review of the potential development sites outlined in Figure 17 associated with Option 3b of the Spatial Strategy Options shows there is a lack of suitable infrastructure to support a significant level of housing growth in this region when compared with other strategic options (e.g. land east of Wickford). Figure 2 of the Complete Communities Topic Paper shows that this area is also less well-served by public transport – highlighting non-frequent bus services and services less than 4 per hour when compared with the high frequency public transport provided on land east of Wickford (tested under Option 3a).
⚫ The land identified for Option 3b within the Spatial Strategy Options is sandwiched between the River Roach to the north, Potton and Foulness Islands to the east, the existing settlement of Southend-on-Sea, and the River Thames to the south and London Southend Airport to the west.
⚫ The only strategic route to and from this area is via the A127 which provides a route
west towards the A130 (north / south route) and the M25. All vehicle redistribution and growth associated with a new, large residential settlement in this area would therefore be required to utilise the A127 as the main route in and out of the area. This route also serves as the main route for London Southend Airport which is due to continue to expand.
The other option for movement into and out from the area is less strategic and comprises the A13 London Road though this would require traffic to travel through
the centre of Southend-on-Sea.
⚫ If a strategic scale of development is proposed then significant new transport
infrastructure may be required, whereby the location of Option 3b presents limitations. For example, the proximity of London Southend Airport to the A127 to the south, and River Roach to the north mean there is very little scope to enhance a connection east from lands north of the town centre.

Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state
reasoning]
Land east of Wickford sits within Rawreth parish but is fundamentally related to and links to
Wickford/Shotgate, lying east of the A130. Engagement with the parish council will be central to
our approach, including how the wider transport, green infrastructure, sports pitches, school and
local centre to benefit existing residents in this area.
Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the
promoted sites should be made available for any of the following uses? How could that improve
the completeness of Rawreth?
Linked with the response to Q63a, the cross-boundary opportunity east of Wickford should be
recognised and allocated as part of the new local plan under whichever strategy option is taken
forward. The opportunities associated with this land allocation are presented in sections 2, 3 and 4
of these representations, supported by the concept masterplan provided in Appendix A.
Essentially, it would comprise a new walkable neighbourhood of around 1,500 homes, employment
plus 2FE primary school and local centre, through removing sites CFS222 and CFS239 from the
Green Belt. A new defensible Green Belt boundary would be established to the west of the A130
and north of the railway line, as shown on the plan enclosed at Appendix B.
Retained Green Belt land under Bloor Homes control – comprising CFS238, CFS223, CFS226, CFS227 and CFS230 – could deliver compensatory improvements to the environmental quality and
accessibility of remaining Green Belt land, including new and improved sports pitches (e.g. CFS222 and CFS226/The Warren), biodiversity net gain, improved walking/cycle links and strategic landscaping.

Dear Sir / Madam,

Please find below my comments regarding the Spatial Options Consultation for your analysis.

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
I could not confirm what were the studies you conducted in order to determine the young people’s needs for leisure activities other than sports. In addition, could you please make available the studies conducted.
Q2. Do you agree with our draft vision for Rochford District?
In a matter of principle, yes, I agree, but there should be a greater highlight to creating new jobs through the establishment of business incubators and support to traditional and new outdoor markets to support local farmers.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
I don’t agree with the separate visions as it will divert the resources from a global vision for Rochford District in terms of number of houses and the respective infrastructure. As such I think it would be detrimental to have a narrower vision which can overlook the effects that the increase of population in one area will have on the remaining parts of the district.
Q4. Do you agree with the strategic priorities and objectives we have identified?
As principles, yes, but I have several objections in the way they are supposedly achieved.
Strategy Options
Q5. Do you agree with the settlement hierarchy presented?
Yes.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
It is my understanding that Option 4 would be preferable, but the more the building is concentrated into one area, the less green belt would have to be released. I will detail my concerns in Q17.
Q7. Are there any reasonable alternatives to these options that should be considered instead?
Please refer to Q6 and Q17.
Spatial Themes
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
Yes, I was not able to verify what would be the dedicated areas for the construction / improvement of roads and other public transport infrastructure. In addition, I could not confirm where will the new waste management facilities (dumps or recycling centres) will be placed, the way the options are presented it does not allow the public to have a detailed understanding of it.
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
Yes. No infrastructure or housing development should be authorised to be built in high floor risk areas or coastal change areas. As the plan is omits what would be the estimated costs in terms of the additional infrastructure that would be required for building in these areas, it doesn’t allow for a risk/benefit analysis of allowing to build in risk areas versus costs that would have to be paid in rates by the general public.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
Yes. In addition, Hockley Woods, Rayleigh Mount and Grove Woods should also be preserved from development.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
I agree, provided that the energy production equipment produces a relevant amount of energy.
There are plenty of opportunities to establish micro-production with community funding. I am not an expert, but please refer to the work done in Manchester in this regard http://www.gmcr.org.uk/ .
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
I agree that energy efficiency should be an important consideration in any development, and they should be above the bear minimum, but I lack the technical knowledge to comment any further.
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?
The Council should encourage companies, charities and individuals to come up with projects and provide administrative and financial support whenever needed to help them see it through.
Considering the availability of surface water and rain in the UK but the lack of natural elevations in the Essex region, consideration should be given to hydro-electric micro-production facilities.
In addition, solar and wind energy should also be encouraged wherever possible.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
Yes. The principle should be applied by areas.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
Yes, 1) there is no point regarding public transport (bike lanes and walk paths alone are nowhere near the needs of the community) and 2) there is no point regarding the minimization of the impact that new roads will have in the fabric of the places they will go through.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
I do not believe that in an area where young people have very few cheap options to buy a house, the option to primarily develop detached or semi-detached housing (80% of the planned houses) would be adequate as the house prices will still be too high, even with the affordable option.
In order to achieve the same number of houses in a significantly smaller development site, the option to increase the number of terraced houses and flats to 50% of the new builds would decrease the overall cost of providing these new houses, regardless of the affordable housing conditions.
In terms of the number of bedrooms, I agree with it, only the distribution between the house size seems too focused in large and expensive properties with a negligible discount that will not suffice to cover the current or future housing needs. A 20% discount on a £700,000 detached house for a family who can only afford a £250,000 terrace house is not an acceptable trade-off.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
In the specific case of Rayleigh where I reside, there is a significant shortage of terraced houses and flats which are by design cheaper than the other options, so in order to meet the new housing needs, development should focus on these rather than creating huge new areas of detached and semi-detached houses that will not meet current housing needs.
Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?
I could not confirm in the plan what areas are being specifically allocated to house rough sleepers and other people in homeless situations.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
Provide that they pay for the land they spend their time on and the facilities and amenities provided by the council and this does not implicate any increase on the council rates through the clear-up of their sites, I do not have any specific input in the solution, although I would think that they would be better placed outside urban areas without sacrificing any green belt area.
Employment and Jobs
Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?
I could not verify if the council is planning or willing to assist new businesses by providing any reduction in business rates for the first years. Considering the crisis that high-street local businesses are facing to establish themselves and thrive, this would be an incredible tool to employ. I am also not aware of any mention to the creation of new business hubs for creative industries, farmers markets and technology start-ups outside of the airport site. When considering the local importance of informal business sites, such as Battlesbridge Antiques Market, the creation of small business hubs would be extremely effective.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt?
As a principle yes, but this has to have a case-by-case analysis of the impacts, namely in terms of polluting employment sites and the needs for infrastructure.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
When establishing the new sites for development, there is an opportunity to require the property developer to establish a commercial presence proportional to the size of the site in order to create basic shopping amenities or go further if the site so justifies in order to attract more retail. For that purpose, the planning must include loading bays in order not to disturb residents and to supply the shops.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Considering that the two main villages in Rochford District are traditionally market towns, it is strange that there aren’t any plans to incentivise more street market initiatives, both seasonal and farmers markets.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
I think more public transport to formal and informal employment sites would greatly stimulate the growth or those sites.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?
The current road infrastructure is already insufficient to move the traffic from the businesses and people going to and from the area adjacent to the airport. In order to increase the ability of the airport to be a major employment site, the roads must be able to allow the circulation of the increased traffic. It is already clear that the construction of an alternative to the A127 or the increase to a dual carriage capacity of an existing road is essential.
Biodiversity
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
Yes, it should include the whole of Hockley Woods.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q33. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Community Infrastructure
Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?
I could not verify where the schools are going to be built and what is going to be increased in terms of the public transport infrastructure.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
Depends on the number of houses built and where they are built. I agree that there has to be an increase, but this seems to be a specialist subject I cannot provide input on.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these?
There is an absolute absence of any facilities for young teenagers that don’t involve organised sports or are not paid.
Regarding the schools and healthcare, the current infrastructure is stretched, and doctors are already struggling to keep up with their appointments as it is and this is a nationwide problem. With new houses being built, this should be addressed before the problem gets even worse, but this is a specialist subject I cannot provide further input on.
Open Spaces and Recreation
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q42. Are there particular open spaces that we should be protecting or improving?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Heritage
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state
Ensure that new types of retail and other businesses are encouraged to establish themselves in the town centres, namely through the reduction or exemption of council rates to give them a chance to survive the initial period. Other than restaurants and beauty services, no new businesses have opened in Rayleigh High Street. This reduces the overall margin of the existing businesses, the attractiveness to the installation of new businesses and the ability to attract visitors to shop in Rayleigh.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
I don’t have an issue with the hierarchy per se, but there should be some protection to the local centres and local parades to ensure that they don’t disappear.
Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. In the town centres the primary use must be commercial as the unchecked conversion to housing developments would create many problems with noise complaints and others where they didn’t exist before.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Yes, as I mentioned before, considering the market town pasts of Rayleigh and Rochford, it would greatly benefit local businesses to incentivise street market initiatives as it would not only provide a greater variety of goods to residents, but it would also provide local businesses the foot traffic.
Transport and Connectivity
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
The plan has to have appropriate measures in place to secure those roads and railways are built ahead of the conclusion of the developments and not after they are concluded, as it is common sense that once the houses are built, any compulsory purchase of space to build infrastructure will be more expensive.
From what I could understand, any plans to increase the transportation network are left to chance or delegated to other entities.
The increase of the housing without transport will further exacerbate the problems that the road infrastructure is currently facing and there are no plans whatsoever to increase public transportation to places which are already lacking, such as Hullbridge which is almost entirely dependent on Rayleigh’s infrastructure.
It is strange that the Beaulieu Estates managed to have a new train line and the people of Rochford District can’t either get appropriate roads, let alone more train connections. I cannot understand how Chelmsford is able to plan these developments to have transport connectivity and Rochford cannot plan a road.
Q52. Are there areas where improvements to transport connections are needed?
Yes, the A127 needs increasing and there is a lack of an alternative route to this road going into Rochford and Southend.
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Yes. All of the above, the increase in the demographics and the expected establishment of new businesses should account for an increase primarily focused on roads, rail and buses that serves as an alternative to the current routes that are massively overrun.
Green Belt and Rural Issues
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Planning for Complete Communities
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
No. I cannot see this translated in the detailed plan.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot understand the allocation between commercial and housing properties as well as infrastructure, as there are nowhere near enough roads or overpasses in the image provided.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate?
No, unless infrastructure is put in place. A simple example is the development in Daws Heath Road, where all these plots are meant to be made available for development, but the end of the road, approaching the A127, is not able to take two cars at the time.
Q56d. Are there areas that require protecting from development?
New developments in the Town Centre that either reduce green areas or affect the Mill Hall and any development that reduces the area of Hockley woods.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
The legend to Figure 44 does not allow for enough detail to understand the changes to the green spaces and the purpose of them.

Q57a. Do you agree with our vision for Rochford and Ashingdon?
I cannot provide meaningful input.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q57d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance?
I cannot provide meaningful input.
Q58a. Do you agree with our vision for Hockley and Hawkwell?
I cannot provide meaningful input.
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q58d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q57e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance?
I cannot provide meaningful input.
Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q60a. Do you agree with our vision for Hullbridge?
I cannot provide meaningful input.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q59c. Are there areas in Hullbridge that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q59d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q59e. Do you agree that the local green spaces shown on Figure 48 hold local significance?
I cannot provide meaningful input.
Q60a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Canewdon?
I cannot provide meaningful input.
Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q61e. Do you agree that the local green spaces shown on Figure 49 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?
I cannot provide meaningful input.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q62d. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q64e. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
I cannot provide meaningful input.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
I cannot provide meaningful input.

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
We feel strongly that a local highways study needs to take place. The document only refers to a study of the main roads in the south Essex infrastructure position statement. This states in 4.2.4 that much of the main road network which leads to our district is operating at, or near, capacity in peak periods.
We cannot understand why Rochford District Council (RDC) would base its planning upon the 2025 flood risk area when developments could reasonably be expected to be in place for more than 100+ years. All evidence from the IPCC and other scientific institutions demonstrate that global sea level rise is a real and presently accelerating threat. In addition, the British Geological survey shows that the Eurasian tectonic plate is tilting along an axis between the Wash and the Bristol Channel, this means that Essex is sinking at a rate of 0.4 to 0.7mm per year (ref. research carried out at Durham University and published in the Journal ‘GSA Today’). These projections are not the worst-case scenario, and the sea level rise could be much worse if climate change continues raising temperatures beyond 1.5 degrees centigrade.
The map generated by Coastal Climate Central for 2050 shows that all of the promoted sites to the west of Hullbridge will be in the flood risk area, and that those to the North East of Hullbridge are also in the flood risk area. RDC needs to ensure that no site at risk of flooding by 2050 is developed.
The Coastal Climate Central 2050 map shows large part of Rochford including Hullbridge below flood levels:
https://coastal.climatecentral.org/map/15/0.6252/51.6246/?theme=sea_level_rise&map_ type=year&basemap=roadmap&contiguous=true&elevation_model=best_available&fo recast_year=2050&pathway=rcp45&percentile=p50&refresh=true&return_level=return_ level_1&slr_model=kopp_2014

Q2. Do you agree with our draft vision for Rochford District?


We believe that the vison should take into consideration the differences in towns and villages; for example, Rayleigh or Rochford may have a more business focus, whereas Hullbridge may be more of a rural community with a greater need to cater for its older population who do not need employment but do need more health services. In principle, the results of this consultation need to feed into it to make specific plans for each settlement.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?


We agree that there should be separate visions for each settlement, however, these should be determined by each Parish Council working with its own residents - this is the appropriate level of localisation. Whilst agreeing with the principle of the localisation approach, it is not visible in the document as a whole. As we have already covered, there should be separate visons for each settlement. In this way it will support planning decisions at a local and district level to ensure the unique character of each distinct settlement remains rather than developing into one indistinct mass.


Q4. Do you agree with the strategic priorities and objectives we have identified?


Strategic Option 2 fails to address the problem of the aging population within the district. This is in large part due to the failure to provide adequate low rent social housing to enable young people to remain in the district and to develop stable family units. The failure of Housing Associations to meet this need is well documented nationally, and locally the largest Housing Association (Sanctuary) has a poor record of maintaining properties and honouring contractual promises made when the RDC’s housing stock transferred. The strategy should provide council housing (preferably directly managed) with genuinely affordable rents and secure tenancies in small local exception sites. There also needs to be provision within these sites for social housing accommodation for elderly residents.
With regard to objective 12 we are concerned that Rayleigh tip has been put forward for development. If so there still needs to be a site for waste disposal close to Rayleigh. The restrictions on vans needs to be lifted to prevent fly tipping.
We believe that sufficient primary school places should be provided within local communities, and steps should be taken to minimise the use of cars to transport children to schools; we are concerned that this is currently not the case.
Strategy Options

Q5. Do you agree with the settlement hierarchy presented?


Yes, the hierarchy seems logical. We feel the strategy should take into account that many more people are working from home, reducing the need to commute to employment centres.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?


It seems that some elements of option 1 and 3 will be required but given the requirement to build more homes the least disruptive option preferred by us would be to go for option 3a. Option 3a has the advantage of being close to the existing road hubs (A127 and A130) and services. It would also be of a sufficient scale to attract section 106 funding for vital infrastructure. 3a would also be close to employment opportunities in Wickford and Basildon.

Option 3b would create considerable pressure on the existing road network and would erode the green belt separation of Southend and Rochford.

Option 3c would place development within the flood risk area and not be sustainable without the need for major road building that would open up the green belt to considerable development in the Crouch Valley.

The building of a major bypass road (as promoted by landowners in the past) to deal with congestion caused by 3b and 3c would destroy the green environment of Rochford and generate further development within the green belt. Development in the villages should be small scale and focussed on providing homes for young families and the elderly.

Small ‘exception’ housing developments added to the village settlements could provide council housing, sheltered housing and bungalows to meet the needs of low-income young families and the elderly. Such provision for the elderly could free up existing houses for younger residents and families to purchase.

Q7. Are there any reasonable alternatives to these options that should be considered instead?


Using option 3a as a starting point, other areas could be developed in future using option 1 when the infrastructure is planned and/or in place.
Restrict overdevelopment in rural and village communities to protect the character of village life.

Spatial Themes

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?


We are concerned about the fact that access was denied to the topic papers, and wholeheartedly believe that the existing lifestyle of the area should be protected from overdevelopment.


Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
We agree that it is imperative that both flood risk and coastal change should be central to any development plans going forward; for us in Hullbridge, many of the proposed sites to the west of the existing settlement are projected to be deep within flooding territory by 2050, as are numerous ones in the east as well. With 2050 now less than three decades away, and no sign of any imminent alteration in the path of climate change, development in any of the areas identified to be in potential flood plains today and in the near future must not be considered.


Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?


The main concern that we have about the Coastal Protection Belt is that it only extends up until 2025 – other areas would need to be included past this date because, as we have mentioned previously, the flood plains across the Rochford district will be vastly different by 2050. It is our view that any and all housing developments proposed in flood plains, current and near future, must not be approved and those that are approved should be given the assurance of protection from flooding over the coming decades. Closer to home, we believe that the river front in Hullbridge should equally be protected for its special landscape character. We would also like to make it known we are very supportive and enthusiastic about the Central Woodlands Arc and the Island Wetland proposals.


Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?


Providing that the development is affordable and deliverable, and the cost is not lumped onto the buyer for many years to come then this is the right decision as the future rests in renewable energy. A solar farm in a place that will not impact its surroundings to solar panels ought to be considered and/or wind turbines on Foulness Island.


Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?


Ideally BREEAM Very Good or Good, as long as the brunt of the cost is not rested on the shoulders of the buyer and that these homes are affordable.

Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?


The installation of wind and solar power generators, in locations such as Foulness, would certainly assist in supporting the local generation of low-carbon and renewable energy which is a necessity in the modern day.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
Yes, these should be settlement specific, to allow for the maintenance of the integrity and specific characteristics of each area, sufficiently detailed to avoid confusion, and widely distributed.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?


Yes, provided individual settlements are consulted and these are adhered to.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes, providing that each individual settlement is at the heart of it and considered as their own entities with their own individual characteristics. It is imperative that certain areas are protected completely, and that any future developers are aware of the identified characteristics of each area.

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?


Design guides should be area specific under one singular guide which is inclusive to the whole district – providing it remains flexible to local conditions.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

As long as the character and aesthetic are maintained concurrently with necessary growth, nothing else needs to be included.

Housing for All

Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?


Meet the need for different types, sizes and tenures of housing (including Affordable, Social, Council and Specialist Housing) by requiring a standard non-negotiable mix of housing to be provided on all housing developments.
New homes should meet the standards set out in Parts M4(2) or M4(3) of Building Regulations.

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?

There is too much focus currently across the district on the provision of 4/5 bedroom properties. This focus needs to shift towards 2/3 bedroom properties which would benefit more local residents/families in search of their first home. "Affordable" homes should not only be flats/apartments but other property types also.
1/2 bed bungalows (or similar) should be a priority, as with an ageing population, there will be increasing demand for such properties when elderly residents are looking to downsize. RDC should actively discourage bungalows being converted into larger properties. Additional provision for residential care is also a priority.
These can all be accommodated within Strategy Option 3a.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?


Affordable homes and social housing to enable single persons or families buy or rent their own home.
Specialist homes for the disabled.
Smaller dedicated properties for the older generation, to enable them to downsize from larger properties, thereby freeing-up larger properties for younger families.

Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs?


The failure to provide traveller sites has led to many unauthorised sites within the green belt being granted planning permission on appeal. With Michelin Farm no longer being an option, RDC needs to identify an alternative appropriate site(s) either from within its ownership or purchased specifically for the purpose. This site(s) should be located so that it (they) does not cause difficulties with established communities; fly-tipping and the impact on nearby residents being just one example. Perhaps, particular consideration of a contained site(s) within the Green Belt, so as to obviate the likelihood of unplanned, piecemeal and unauthorised sites fragmenting the green belt.
Consideration also needs to be given to the fact that there are different groups within the Traveller communities who do not want to be placed together and perhaps ways can be found to integrate these into everyday life and housing.

Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?


Some Traveller Groups tend to make their own arrangements to use owned land on a temporary basis. RDC needs to identify a site(s) either from within its ownership or purchased specifically for this purpose. It (they) would need to be sufficiently away from residences that they would not be disturbed or troubled by vehicles/caravans arriving or leaving. Perhaps a pre-payment/booking system could be introduced for this purpose and at the same time, reducing the likelihood of over-crowding.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
Locate sites close to main roads to enable easy access for large vehicles, so that residential roads are not congested and nearby residents are not disturbed. Allow a little room for expansion and limit the likelihood encroachment onto neighbouring land.
Locate away from spaces of national, regional, local or community interest or recreation, so as not to spoil the visual amenity of the landscape.
The sites should not be closed and available to the whole Traveller community.

Employment and Jobs

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?


In addition to employment option 11 which states: Working with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages, information should be collected and made available on where there are shortages or opportunities coming up. Offer advice to adults wishing to or needing to reskill. Provide local affordable adult education courses on the skills needed. Work with employers, education centres and Essex County Council.

With reference to employment option 4 that states: Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments. This should apply to the larger scale developments described in spatial strategy option 3. Employment option 4 goes on to specify live work units as an option. This would help with increasing numbers of people working from home. Also start up business centres and co-working spaces would be useful and there are many self-employed people and small businesses in this area. A sympathetic attitude is required towards people running a business from home provided that the impact on the surrounding area is minimal.

In all of this we need to be mindful of paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the green belt?


Consider any brownfield site for employment use these are currently mainly getting used for housing. There needs to be employment opportunities even in the smaller settlements if we are going to be greener and cut down on transport use. Employment option 6 states: Meeting future needs by prioritising the regularisation of informal employment sites such as those shown on figure 30. This would make employment accessible to people living in the rural communities especially if other farms able to do this could also be identified. Most of the sites are in the western half of the district it would be useful to identify a few more sites in the east to make this a policy that serves the whole district.

Any use that is not heavily disruptive to the surrounding area should be permitted. Planning officers should be able to permit reasonable adjustments requested by residents to make extensions and adaptations to their homes to accommodate working from home or running a business from home.

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?


Our preferred spatial strategy option is 3a. Concentrated growth is required to bring the necessary infrastructure to make business and employment growth viable. There needs to be links to main roads to accommodate the commercial traffic required to service industry. Improvements to public transport to employment sites are needed.

Employment option 4 which states: Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments, could be delivered by strategy 3a.

Employment Strategy 6, which meets future needs by prioritising the regularisation of informal employment sites, would help deliver more businesses and employment. Employment option 3 refers to Saxon Business Park, Michelin Farm and Star Lane; we should continue to expand and improve these sites. However this needs to be done in conjunction with other options not as a stand-alone policy. These two strategies are needed and can be included in any of the spatial options.

Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?


Sites set aside for education and health uses in addition to the services they provide, they also provide good employment opportunities. Sites also for High and Low Technology. Foulness would be ideal for green industries.

Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?


Provide appropriate schools and colleges to serve the increase in population due to high development, but locate with public transport links and accessibility by walking or cycling in mind. Also work with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages as stated in employment option 11.

Work with bus companies and Essex County Council to make our existing employment sites as accessible as possible. Improve footpaths and cycle tracks using government funding applied for by Rochford District Council. Move away from planning employment sites in places that are designed to be accessed by car use. Some employment is going to have to be close to settlements. This of course would have to be take into account paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?


Protect the airport and encourage airport linked transport adjacent or close to the airport eg, existing airport industrial park and Saxon Business Park. Both airport growth and industry will promote jobs.

The transport system both road network and public transport needs to be improved to make these growing opportunities accessible for all.

Biodiversity

Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?


YES

While Hockley Woods does not seem to be mentioned here, we would have thought this ancient woodland (and similar woodland), and its important wildlife habitat should be included as it provides for a number of rare species including lesser spotted woodpeckers and hawfinches.

The lower Crouch Valley, the River Crouch and its banks are important habitats for fauna including birds that are on the endangered species red list. This includes curlews, whimbrels, and other wading birds. The pasture land flanking the Crouch towards Battlesbridge is an important habitat for skylarks and other species; these areas should be protected.
Restrict development in all other green belt areas, in order to protect nature. Alongside this, provide protection for nature reserves, parkland and areas fronting rivers.

Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection


Yes, as we have already stated, many areas provide habitats for endangered or rare wildlife and therefore are more than worthy of protection.

Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?

Onsite reduced developments in general will assist moving new developments to high unemployment areas.
We agree with the central woodlands arc and island wetlands proposals.

Green and Blue Infrastructure

Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?


More investment is required in many areas of infrastructure, from roads to general services. It would be beneficial to green ideals to restrict or ban development in or near green belt sites and to keep development in the rural areas to a minimum.

Q33. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?


By lobbying central government to allow revision of RDC plans to support a quality green and blue infrastructure.
Q34. With referene to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?


Concentrate on brownfield and town sites in order to protect rural communities and the green belt – as previously alluded, options 3 or 4 mean less development in rural areas and are therefore more accommodating to the needs of smaller rural areas like Hullbridge, hence our choice of option 3a.

Community Infrastructure

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?


Build property where there is existing infrastructure or where infrastructure can be expanded without encroaching on green belt etc.
A survey needs to be carried out on local roads to determine what is needed to be upgraded to achieve any sustainable way for traffic, both domestic and that which uses these as through roads.
With reference to Hullbridge much of it is unadopted roads and cannot support any development, let alone be able to accommodate the use of these roads as through roads for both building access and ultimate through road access to any development.

Provide schools for development areas and provide transport links to these schools. Local schools, both primary and secondary, are already struggling with the increase in pupil numbers coupled with limited capacity.

Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?


Funds were given via section 106 to expand Hullbridge Healthcare Centre and provide more school places - neither of these has happened. The section 106 money from the existing Malyons Farm development urgently needs to be made available to both the Hullbridge Healthcare Centre and the Hullbridge Primary School.
More development would make the situation untenable, particularly if further section 106 monies were withheld by RDC and not allocated to benefitting the local community where new developments are built.

Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these?

Even with section 106 grants, if made available, healthcare facilities in Hullbridge are severely restricted, especially since the pandemic due to doctor shortage. Further development in Hullbridge would worsen healthcare provision and, even with section 106 grants if released by RDC, will not improve the situation.
Whilst this is outside the control of RDC, developments would cause serious issues particularly as Hullbridge traditionally has an ageing population - one which is obviously more reliant on healthcare, alongside the inevitability of new patients from current and any new developments.
There are currently inadequate or no existent bus and footpath links to areas east of Hullbridge, such as the Dome Area. Any development to the east of Hullbridge would have transport difficulty and also the impact on Lower Road would be unacceptable; this would be the case even bus links were improved.
The same approach needs to be taken with schools and highways and new residents could be short- changed without easy access to schools, healthcare and employment.
Open Spaces and Recreation

Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?


With reference to open spaces and recreation option 5, we should improve and maintain what we already have, using section 106 money for improvements. We should ensure that any section 106 money does get spent how and where it was intended. No section 106 money should end up being unused.

We should improve bus links to existing facilities in the district, for example Clements Hall where buses used to run in the past (at least in the school holiday periods). There should be an aim to provide permanent all year-round bus services to our main leisure sites.

The Hockley ‘Park Run’ is very popular. Should the proposed Central Woodlands Arc come into being it would be ideal for a park run. Orienteering could be an interesting additional activity; local scouting groups, and schooling groups too, would certainly benefit from this.

Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?


We should ensure that any proposal for a 3G pitch has the backing of local residents. For reference, in 2016 a 3G pitch was applied for planning permission by The Fitzwimarc School but turned down by Rochford District Council due the objections of local residents.
The Hullbridge Recreation Ground would be ideal for a new 3G pitch.

Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?


Primary Schools should also be considered along with any site that could host a hockey or a 5 a side pitch.

Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?


Our preferred spatial strategy option is 3a. The section 106 money that comes with the larger developments has more chance of providing good sustainable new facilities.
A bus service needs to be run to facilities like Clements Hall, at least during half term and school holidays, to enable young people to access it from areas where it is currently difficult to access by public transport; this has been done in the past to access sports and in particularly swimming facilities which are not available in Hullbridge or Rawreth.
Swimming facilities were excluded from the Rawreth Lane sport facility.

Q42. Are there particular open spaces that we should be protecting or improving?


Hullbridge Recreation Ground. Our nature reserves, parks and woodlands to promote walking and other appropriate exercising activities.

Heritage

Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?


Protect village and rural areas from over or inappropriate development through careful planning considerations.

Compose a list of sites with local consultation. Then look maintain them with local residents and organisations.


Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?


Villages fronting riversides: Hullbridge, Paglesham, Canewdon, South Fambridge.

Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?


As with protected sites a consultation needs to be done for each locality. With reference to Hullbridge, in addition to the old school, Shell Cottage and River Cottage are already listed. We would add the school house next to the school, Brick Cottages, Tap's Cottage and the Anchor Cottages if they are not already listed/locally listed buildings.

Town Centres and Retail

Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state]


Market forces are moving purchases online so town centres need to be more accessible and convenient to encourage day shopping, and also increase night time business where appropriate to take up capacity lost from retail.

Improve transport links to town shopping and amenities. There is no transport link from the Dome that would take their residents into nearby Hockley for example. There are no easy transport links from Hullbridge to Hockley or Rochford.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]


Protecting businesses generally will not work as commercially if they are not profitable, they will close and we will have empty shops. Rochford District Council needs to encourage business with free parking and reduced business rates.

Businesses should be encouraged to work together with a co-operative nature, or a number of shops all open a little later one night of the week to make it worth shoppers coming out in the early evening. Local eateries could offer special deals on those nights.

Community events that encourage shops and businesses to join in – fairs, celebrations, etc.

Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]


Keep streets clean and tidy, and repair and repaint street furniture regularly. Conserve the character of the town centres by avoiding high rise development and buildings that are at odds with the street scene.

Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]


Some existing ok but links to, e.g., Clements Hall from Hullbridge non-existent.

Businesses cannot be forced into staying unless benefits outlined in Q47 are adhered to which may encourage some business opportunities and current business to remain.

Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]


Spatial strategy 3a will give the most opportunity to expand retail both in terms of including retail space and bringing customers into the town centres nearest to the new developments. The document mentions a cinema. The best site for this would be Saxon Business Park. A bowling alley would work well with this alongside some eateries.

Transport and Connectivity

Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?


Certainly, prepare an Infrastructure Delivery Plan that would deliver meaningful improvement to transport networks, including but not exclusively, cycle routes, walking pathways, public transport and roads. However, all these modes are currently completely stretched; modernisation and improvements to all need to happen before future housing developments are built. It should be noted that following the last developments in the Core Strategy, as far as Hullbridge is concerned (and almost certainly elsewhere also), the promised improvements have either not materialised, been completed or proven to be inadequate.
The plan needs to deliver improvements to public transport by working with bus companies to re-establish bus routes to isolated communities that have been either been terminated or severely curtailed. For example, ‘The Dome’ has a bus service twice a week. Residents regularly complain that they are isolated from everywhere else. It is also claimed that Hullbridge has its own bus service that runs 4 - 7 times a day. This is not the experience of Hullbridge residents and it only needs the slightest issue along Hullbridge Road for the service to either be even further curtailed or suspended entirely.
RDC need to continue to work with Government, Highways England, Essex CC etc to deliver meaningful road improvements to both the main road arteries and to the local road network. However, any large-scale bypass scheme such as the "Southend Outer Bypass" scheme needs to be opposed. Not only would it cut directly through the Green Belt but it would increase development along its course, which in turn would have enormous negative impact on the Green Belt itself, natural habitats and the environment generally.

Q52. Are there areas where improvements to transport connections are needed?


Whilst some improvements are shortly to commence at the Fairglen Interchange and A130, further improvements are needed to the Junction of Rawreth Lane and the A1245. Perhaps also the A127 could be widened along its length from four lanes to six lanes.
Additionally, the bus service between Hullbridge and Rayleigh can be cut with the slightest issue along Hullbridge Road and this needs to be addressed urgently. When this happens it consequently results in more vehicles using Hullbridge road, which in turn exacerbates traffic congestion and leads to other problems such as pollution.
A bus service between Rochford and Rayleigh via Hullbridge and Hockley and Rayleigh via Hullbridge would serve to reduce traffic congestion along Lower Road, especially at "rush" hours. This would benefit residents of the Dome as well as properties along the length of Lower Road. It would also serve to provide access for Hullbridge students to access the Greensward Academy that does not exist currently.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Improvements to existing road networks. Large scale bypass schemes, such as the “Southend Outer” bypass would be unacceptable because of the hugely detrimental impact on the Green Belt and its physical and natural environment.
Small low top busses to link smaller communities with larger ones. Trams not a viable option for the more rural areas as roads are too narrow and winding; additionally, would increase congestion on existing roads.
Improvements to the cycle path network, extending and linking the network as and where appropriate and safe.

Green Belt and Rural Issues

Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided?


Yes, but not within the Green Belt and Rural and Village life must be safeguarded.
Any such sites must be small scale and have developments that prioritise genuinely "Affordable" homes and/or Social Housing that would benefit local residents/families most.

Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
Support changes that would require developers of 10 units or less to pay something akin to s.106/CIL monies, that would go towards infrastructure improvements, particularly those affecting rural communities.

Planning for Complete Communities

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?


N/A


Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate?


N/A


Q56d. Are there areas that require protecting from development?


N/A


Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?


N/A

Q57a. Do you agree with our vision for Rochford and Ashingdon?



N/A

Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate?


N/A


Q57d. Are there areas that require protecting from development?


N/A



Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance?

N/A

Q58a. Do you agree with our vision for Hockley and Hawkwell?

N/A

Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?

N/A

Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?


N/A

Q58d. Are there areas that require protecting from development?


N/A



Q57e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance?


N/A


Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]

N/A

Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A




Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A





Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A


Q60a. Do you agree with our vision for Hullbridge?


We do not agree with the wording or the aims of the provided vision statement for Hullbridge and have instead drafted our own (see below). We were sceptical about the suggestion that the river could be used for transport without consideration on the viability or environmental impact of this proposal.

Hullbridge will have expanded on its already self-reliant nature, boasting impressive local businesses and amenities – providing a perfect space for those who wish to enjoy their retirement as well as those with young families. Through small, localised and respectable developments, the thriving community and riverside aesthetic of the village remains as strong as ever; all of this has been achieved through the transparency and openness of different local authorities, residents, businesses and developers on any and all developments going forward.

Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2050 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.

Q60c. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


All of the areas lie within the green belt, and many will be within the projected 2050 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.

Q60d. Are there areas in Hullbridge that development should generally be presumed appropriate?


Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.

Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there areas that require protecting from development?


Yes, all of those identified as such in Figure 48 are definitely areas of local significance and are correct to be identified as such. Other areas that should be outlined include the Rose Garden, the banks of the River Crouch and the upcoming green space and Memorial Gardens provided as part of the recent Malyons Farm development.

Q61a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]


N/A


Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Canewdon?


N/A


Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]

N/A

Q61e. Do you agree that the local green spaces shown on Figure 49 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A



Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]


N/A


Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?


N/A


Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]

N/A



Q62d. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A



Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]


N/A





Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A


Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]


N/A


Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A

Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]


N/A


Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A






Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]


No - All communities should have their own individual, locally determined vision statements, especially the more rural ones. Each settlement has its own distinct character and the vision statement would serve to aid the planning process in safeguarding their individual character.

Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]


Yes in the broadest terms. We would want it to re-iterate that the individual character and seeming uniqueness of our rural communities needs to be, and will be, safeguarded. By extension, we would like to see more activity in this regard from all tiers of Government.

Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?


Respect the green belt that surrounds our rural communities and our higher tier settlements; thereby ensuring a buffer ("defensible boundary") that would actively prevent communities merging into one conglomeration.

Create a Country Park to the west of Hullbridge.

Improve village roads, transport, educational and utility infrastructure. All of which are already in desperate need of improvement and renovation. For example, it is questionable whether the sewerage system in Hullbridge could cope with any further development without expansion and upgrading.

I am writing to express my concerns regarding the proposed plans within the Spatial Options Consultation 2021. The plans for additional housing developments will further reduce the green spaces locally and infringe upon greenbelt land.
A brief word about the consultation itself; while the documentation has been made available and residents have been informed, I do not believe that it is presented in a manageable or accessible format. There is a plethora of information the questionnaire is very long, and the language used is formal, wordy, and fairly technical in nature. I expect that despite many residents having concerns many will not respond as they will see it as too time-consuming and impenetrable.

An uncertain future
Given the upheaval caused by the pandemic this is probably not the time to make firm plans for the next 20 years. We have been going through a period of huge change. The way we work and live are likely to be affected for some time to come, some changes will be permanent with more people working from home some or all the time. In turn this means that the use of office and retail space will change significantly. More people are moving towards online shopping and gradually retailers are improving the online shop experience. These changes are likely to free up space for redevelopment of existing office and retail space into residential use. I believe that rather than building on green field sites we should consider a more conservative approach to wait to see whether the effects of the pandemic mean that existing sites can be redeveloped. Once the green field sites have been used, they are gone. Furthermore, the pandemic has highlighted the need for areas of nature for recreation and health. It can surely not be wise to shrink these areas while adding to the population? This cannot have a positive effect on the health and wellbeing of the local population.

Local character, Historic Towns
The character of the local area is being gradually eroded with the green spaces between towns such as Rochford, Hockley, and Rayleigh dwindling. If the proposed blue sites on the interactive map https://rochford.opus4.co.uk/ you have provided were to be used for development the area is close to becoming one large conurbation. Thus, the towns will lose their character and simply become areas within a larger whole.

Greenbelt
There are many proposed sites that appear to sit within, or directly on or adjacent to the boundaries of Metropolitan Green Belt land. These appear to include, CFS07L, CFS027, CFS053, CFS160, CFS134, CFS002, CFS045, CFS251, CFS074, CFS082, CFS078, CFS080, CFS081, CFS135, CFS064, CFS264, CFS040, CFS160, CFS105, CFS024. Moreover, some of these sites would appear to involve building within Marylands Nature reserve in Hockley (CFS024) or within Hockley Woods (CFS160) or next to the boundary of Betts Farm ancient woodland and Folly Wood (CFS064). This would obviously cause immense damage to the natural environment, loss of ancient woodland and potential loss to rare species. Even if the woodland itself is not built upon the disruption to the site while building work is taking place and the loss of linking areas of open land will have a detrimental effect on the woodland environment, causing fragmentation. Studies done by charities such as The Woodland Trust state that inappropriate development of land adjacent to woodland can cause chemical pollution, disturbance to wildlife, fragmentation, introduction of non-native plants and other negative cumulative effects. Please see: Threats to woods and trees - Woodland Trust
I would draw your attention to the following paragraph within The National Planning Policy Framework revised 20th July 2021.
“13. Protecting Green Belt land 137. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 138. Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land”
And
“Proposals affecting the Green Belt 147. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances”
Within The draft vision for Rochford in 2050 Strategic Priority 5 is “Making suitable and sufficient provision for climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape”. I believe the plans for housing developments within the green belt will directly obstruct this priority.


Congestion, Pollution, Gridlock
An area of huge concern amongst residents is the effect of all the additional traffic created both during the building of new developments and once built from the increased traffic caused by increased population. Infrastructure in the local area is woefully insufficient already. The B1013 links Rochford, Hawkwell, Hockley and Rayleigh. Greensward Lane and Ashingdon Road link to this road. Should further housing be added to the area the pressure on these roads will be immense. There will be further delays, additional pollution, and road traffic accidents. There is already severe traffic especially at peak times along these roads. One small accident can cause gridlock. Rochford District Council is fully aware of these issues as they have been raised time and time again by residents.

In conclusion I implore you to consider carefully the impact of further residential developments on the infrastructure, character, and green field sites of our area. Examine meticulously the emerging trends due to the effects of the pandemic and our increasing dependency on information technology and take a far more conservative approach to the management of our open spaces.

Q1. Are there any other technical evidence studies that
you feel the Council needs to prepare to inform its
new Local Plan, other than those listed in this section?

The Council would expect to see specific reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are vital to the long-term sustainability assessment of any proposed sites. Without these
we are unable to comment
Evaluation of the impact of current development on the town of Rayleigh
Rochford District Council should produce its own estimate of Housing need with which to Challenge the figures imposed by Westminster, it is known that the nearest neighbours have all done this.
The Town Council cannot comment on the suitability of the sites in the plan without completion of an
Infrastructure Delivery and Funding Plan which is being undertaken at present, why has this consultation been undertaken before this is available. RDC, ECC, and SBC,
I would expect it to see specific reference to
i) the main Roads and the principal junctions and exit points to Rayleigh, there is potential in this
plan is to build on London Road, Eastwood Road, Hockley Road and Hullbridge Road simultaneously.
ii) Consultation with the actual schools in Rayleigh as to capacity, too often there are no places in
specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, again there is
evidence of no capacity in certain parts of Rayleigh.
iv) Next level HealthCare such as Hospitals, need consulting, as they are overstretched.
v) Air Quality Management - too many parts of Rayleigh have poor CO2/CO readings
Any such Plan would need agreement with Rochford District Council, Essex County Council, and
Southend Borough Council as they are all affected

Q2. Do you agree with our draft vision for Rochford
District? Is there anything missing from the vision that
you feel needs to be included? [Please state
reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for
the hidden homeless or those on low incomes, schemes to allow the elderly in large houses to be able
to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses
to up or downsize into a suitably sized premises without them needing to relocate into another area.
No provision for emergency housing.

Q3. Do you agree that we should develop a range of
separate visions for each of our settlements to help
guide decision-making? [Please state reasoning]
Yes, as each settlement has its own characteristics and needs.

Q4. Do you agree with the strategic priorities and
objectives we have identified? Is there anything
missing from the strategic priorities or objectives that
you feel needs to be included? [Please state
reasoning]
No comments.

Q5. Do you agree with the settlement hierarchy
presented? If not, what changes do you think are
required? [Please state reasoning]
Yes. Rayleigh is the largest town in the district but care needs to be taken to maintain the integrity of
the existing settlements with respect to green boundary between Rayleigh and its neighbours.

Q6. Which of the identified strategy options do you
consider should be taken forward in the Plan? [Please
state reasoning]
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for
cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening
in the larger town (and proposed in option 1), creating traffic havoc and pollution. A single large
"garden" village, possibly shared with Southend could allow a more environmentally friendly
development. A development that allows the infrastructure to be developed in advance of the
housing.

Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state
reasoning]
Small development and windfall developments should be included in housing count.

Q8. Are there any key spatial themes that you feel we
have missed or that require greater emphasis? [Please
state reasoning]
Yes: Cultural and Accessibility.

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating
development away from areas at risk of flooding and
coastal change wherever possible? How can we best
protect current and future communities from flood
risk and coastal change? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, their houses and businesses but also the natural areas as well. The district needs adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas.
New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc.
The plan must include or identify a flood plane that is protected from development.

Q10. Do you agree that the Coastal Protection Belt and
Upper Roach Valley should be protected from
development that would be harmful to their
landscape character? Are there other areas that you
feel should be protected for their special landscape
character? [Please state reasoning]
All the coastal areas and areas of special interest, especially where there is a significant risk of
flooding and harm to the environment need careful consideration.
The Ancient woodlands such as Kingley Woods, Hockley Woods and Rayleigh Grove Woods and all
natural parks, not just the actual woodlands but also the surrounding areas

Q11. Do you agree we should require development to
source a percentage of their energy from low-carbon
and renewable sources? Are there other opportunities
in the district to supply low-carbon or renewable
energy?
Yes.
New developments should be able to source some or all of their energy from renewable sources.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than
building regulations? What level should these be set
at? [Please state reasoning].
Yes. The Town Council believes that you should aim to achieve a higher standard if possible and
encourage developers to put forward new ways of achieving this. You must plan for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher! Keep the technology under review to capitalise on new development.

Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation
should be supported? [Please state reasoning]
Solar in all new development as standard. Incentives to encourage existing developments to install
solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs;
there are many flat roofed buildings all over the district that could accommodate solar panels without
damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain
whether it is viable. Retrofitting existing housing and commercial buildings

Q14. Do you consider that the plan should include a placemaking charter that informs relevant policies? Should the same principles apply everywhere in the district, or should different principles apply to different areas? [Please state reasoning]
The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered
in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and again, SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.

Q15. Are the principles set out in the draft place-making
charter the right ones? Are there other principles that
should be included? [Please state reasoning]
They are, as long as they are adhered to.

Q16.
a. Do you consider that new design guides, codes or
masterplans should be created alongside the new
Local Plan?
Yes.
b. If yes, do you think it is more appropriate to have a
single design guide/code for the whole District, or to
have design guides/codes/masterplans for individual
settlements or growth areas? [Please state reasoning]
You need different design guides as this district is both unique and diverse and the “one shoe fits all"
would be detrimental to its character and charm.
c. What do you think should be included in design
guides/codes/masterplans at the scale you are
suggesting? [Please state reasoning].
You need to ensure that the character and heritage of the settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.

Q17. With reference to the options listed above, or your
own options, how do you feel we can best plan to
meet our need for different types, sizes and tenures of
housing? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities,
residents and businesses. You will then get a better understanding as to what you need and what will
be achievable.

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure?
What is required to meet housing needs in these
areas? [Please state reasoning]
The district has a large number of houses, existing and approved that have four or five bedrooms. The number of homes available with two or three bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. You must ensure that the “affordable“ properties are not all flats and that minimum or higher standards are
met for gardens and recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living, residential or retirement homes. They may want a one or two bedroomed property, maybe one storey, or low-rise apartment that they own freehold. The Council would like to safeguard the number of smaller bungalows available and make sure that the existing stock is preserved and a suitable number are provided in the housing mix. You need to consider that some residents may need residential care and you should be looking at ways to cope with the rising number of elderly and provide accommodation for them also.
Consideration should be given to the provision of house for life, bungalows and other potential buildings for downsizing families.
The plan makes no reference to social housing quotas.
The district desperately needs to meet the needs of the hidden homeless. People like the adult children on low wages who have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. You also need accessible properties for the disabled members of our community, where they are assisted in order to fulfil a normal as possible life. All these issues, and perhaps many more, need be addressed.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state
reasoning]
Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled. Smaller, freehold properties for the older generation to enable them to downsize from large family homes. Emergency housing.

Q20. With reference to the options listed, or your own
options, what do you think is the most appropriate
way of meeting our permanent Gypsy and Traveller
accommodation needs? [Please state reasoning]
You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and you should revisit the criteria for the traveller community to meet the legal requirements. Strong controls are needed to prevent illegal building work and to ensure the site populations do not exceed capacity.

Q21. With reference to the options listed, or your own
options, what do you think is the most appropriate
way of meeting our temporary Gypsy and Traveller
accommodation needs? [Please state reasoning]
See answer to Q20

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations
for new Gypsy and Traveller sites? [Please state
reasoning]
See answer to Q20.

Q23. With reference to the options listed above, or your
own options, how do you feel we can best ensure that
we meet our employment and skills needs through
the plan? [Please state reasoning]
The council should stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. Consider how the plan can help those businesses wanting to expand. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes to train all ages get back into work or upskill. Developers should be encouraged to use local labour

Q24. With reference to Figure 30, do you consider the
current employment site allocations to provide
enough space to meet the District’s employment
needs through to 2040? Should we seek to formally
protect any informal employment sites for commercial
uses, including those in the Green Belt? [Please state
reasoning]
No. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. The plan should only formally protect sites the that have a future and a
potential to expand or continue effectively.

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
employment facilities or improvements to existing
employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26. Are there any particular types of employment site or
business accommodation that you consider Rochford
District is lacking, or would benefit from?
Environmental services - woodland conservation and management. (We need to find funding for this
as it is important!) HGV training school and modern transport training. Improve manufacturing base.
Q27. Are there other measures we can take through the
plan to lay the foundations for long-term economic
growth, e.g., skills or connectivity?
Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs
at the end of training. CCTV where appropriate.
Q28. With reference to the options listed above, or your
own options, how do you feel we can best manage the
Airport’s adaptations and growth through the
planning system? [Please state reasoning]
No comments.
Q29. Do you agree that the plan should designate and
protect areas of land of locally important wildlife
value as a local wildlife site, having regard to the Local
Wildlife Sites review? Are there any other sites that
you feel are worthy of protection? [Please state
reasoning]
Yes. You should conform to and improve existing RDC policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing
development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings. These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are
the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30. Do you agree that the plan should designate and
protect areas of land of locally important geological
value as a local geological site, having regard to the
Local Wildlife Sites review? Are there any other sites
that you feel are worthy of protection? [Please state
reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31. Do you consider net gains for biodiversity are best
delivered on-site or off-site? Are there specific
locations or projects where net gain projects could be
delivered?
On site. You can then assess in real time and sort out any issues you would not have known about off
site.
Q32. With reference to the options above, or your own
options, how do you feel we can best deliver a quality
green and blue infrastructure network through the
plan? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as
well as providing new spaces and facilities. The sites should be well-maintained.
Q33. Do you agree that the central woodlands arc and
island wetlands, shown on Figure 32 are the most
appropriate areas for new regional parklands? Are
there any other areas that should be considered or
preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced. Existing sites must be retained
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new
strategic green and blue infrastructure? [Please state
reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities
within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
Q35. With reference to the options above, or your own
options, how can we address the need for sufficient
and accessible community infrastructure through the
plan? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning
and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or
improved community infrastructure? [Please state
reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have
particularly severe capacity or access issues relating to
community infrastructure, including schools,
healthcare facilities or community facilities? How can
we best address these? [Please state reasoning]
Rayleigh is overcrowded; it has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer
capable of expanding to meet the needs of an ever-growing population. The plan should also identify
a site to accommodate commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own
options, how do you feel we can best meet our open
space and sport facility needs through the plan?
[Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39. Are the potential locations for 3G pitch investment
the right ones? Are there other locations that we
should be considering? [Please state reasoning]
All-weather facilities should be considered
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should
be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver
improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42. Are there particular open spaces that we should be
protecting or improving? [Please note, you will have
an opportunity to make specific comments on open
spaces and local green spaces in the settlement
profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back.
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best
address heritage issues through the plan? [Please
state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage
list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they
have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to
those with impaired sight or mobility.
Q44. Are there areas of the District we should be
considering for conservation area status beyond those
listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing. Sites within the existing Rayleigh Conversation Area should not be considered

Q45. Are there any buildings, spaces or structures that
should be protected for their historic, cultural or
architectural significance? Should these be considered
for inclusion on the Local List of non-designated
assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46. With reference to the options listed above, or your
own options, how do you think we can best plan for
vibrant town centres in Rochford, Rayleigh and
Hockley? How can we also ensure our village and
neighbourhood centres remain vibrant? [Please state
reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe
offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local”
business only – allowing the entrepreneurs in the Rochford District a chance to showcase their
businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies. Any plan should be reviewed frequently; at least every 5 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new
business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
[Please state reasoning]
Yes
Q48. With reference to Figures 38-40, do you agree with
existing town centre boundaries and extent of
primary and secondary shopping frontages in
Rayleigh, Rochford and Hockley? If not, what
changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary
shopping frontages within those centres? If yes, what
uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved
retail and leisure services in the District? [Please state
reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size. Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the
area.
Q51. With reference to the options above, or your own
options, how do you feel we can best address our
transport and connectivity needs through the plan?
[Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention
Q52. Are there areas where improvements to transport
connections are needed? What could be done to help
improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes
proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is
now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a
cycle network as part of the plan.
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
transport connections, such as link roads or rapid
transit? What routes and modes should these take?
[Walking, cycling, rail, bus, road etc.]
As the preferred strategy option is 3b, this could create opportunities for improved links to Southend. You should also consider more and smaller buses to link the towns and villages. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a
complete review of sustainable transport.
Q54. Do you feel that the plan should identify rural
exception sites? If so, where should these be located
and what forms of housing or employment do you feel
need to be provided? [Please note you may wish to
comment on the use of specific areas of land in the
next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
[Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a. Do you agree with our vision for Rayleigh? Is there
anything you feel is missing? [Please state reasoning]
The plan is adequate so far is it goes, but you have more work to do. You must plan for a reduced volume of traffic and air pollution. More attention is needed to initiatives that design-out crime and fear of crime, and this needs to be functional, sustainable and viable. The Draft Vision Statement ignores the over-development, the lack of infrastructure and facilities we already suffer. Indeed, Rochford District Council’s stated aim within their Asset Strategy and the plans of other Public Service providers is to reduce facilities in the Town further. This is at the same time as demand is growing from a sharply increasing population. This is particularly relevant for the growing elderly population. This will make the next 25 years very challenging.
1/ Cycling infrastructure and other sustainable transport methods should be prioritised over a carcentric highway use. We regret we do not because it is unrealistic, our response must be to inject a note of realism looking forward based on RDCs policies and past action. This goes to the heart of the new Local Plan.
We regret a realistic Vision Statement based on the current trajectory of further development recommended in the Draft Local Plan will be rather more dystopian. We could see a Rayleigh chocked by traffic. Although pollution should decrease with electric vehicles the advent of driverless vehicles, both domestic and commercial, servicing an ever-expanding population could result in gridlock. Pollution will increase from fossil burning home heating systems in many of the new homes. Failure to support public transport will inevitably maroon older residents in their homes far from those few
facilities and shops that remain in our town centre.
Public services offered by police and council (most likely giant unitary council catering for half million people based far away in an urban area), will seem very distant to most people. Most of the green open spaces not in public ownership, also some that are publicly owned, will be built on and have disappeared by 2050. Many public facilities and local public service providers will be taken away and sold off to property developers. The town centres will cease to be the shopping and social areas we know today as a result of Council plans and changing shopping habits. Rayleigh retail business will have closed and online and out of town retail parks will prosper with their free parking facilities. In the same way that London boroughs developed through the decades and centuries, the traditional housing we know today, with private gardens will be replaced by blocks of flats with large vehicle parking areas with recharge points.
2/ Another vision could be forged with the right policies in an enlightened Local Plan. RDC could opt for a garden village settlement away from all the Districts Towns and villages. Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made
cheaper to assist local town centre business to survive what will be a challenging period. Secondary
shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Council Offices, Police Station and Library etc. The town centre should be the heart of our community not just something you drive
through to reach somewhere else. This could be our vision and our aim for the future.
b. With reference to Figure 44 and your preferred
Strategy Option, do you think any of the promoted
sites should be made available for any of the following
uses? How could that improve the completeness of
Rayleigh?
Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial [offices, industrial, retail, other]
Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure [open space, education, healthcare, allotments, other]
Community infrastructure should be preserved and extended. Access to town centres and secondary
shopping by bicycle and foot should be made easier and safer.
c. Are there areas in Rayleigh that development should
generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called
windfall development should be incorporated in the overall development targets thereby reducing
large scale development.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e. Do you agree that the local green spaces shown on
Figure 44 hold local significance? Are there any other
open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets
Q57.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Hockley Wood
Q58.
a. Do you agree with our vision for Hockley and
Hawkwell? Is there anything you feel is missing?
[Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
Q58.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
As Hockley Woods is the largest remaining wild woodland in the country you should be doing
EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status. You must protect any thoroughfares that access Hockley Wood.
Q60.
a. Do you agree with our vision for Hullbridge? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Anything too close to the river due to flood risk.
e. Do you agree that the local green spaces shown on
Figure 48 hold local significance? Are there any other
open spaces that hold particular local significance?
[Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the
Governments home building targets
Q63.
a. Do you agree with our vision for Rawreth? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
c. Are there areas in Rawreth that development should
generally be presumed appropriate? Why these
areas? [Please state reasoning]
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Protection needs to be given to development that change the dynamics of the village and those areas that border Wickford. There needs to be a significant amount of green belt land left to separate the two areas to prevent urban sprawl. Rawreth Lane gets heavily congested at peak times, and with Wolsey Park still not complete this is likely to increase. If there is an accident or breakdown on the road network, it has a huge knock on through Rayleigh and the surrounding areas and Watery Lane isn’t a reliable back up for when there are issue. Therefore, further development on the boundary or
otherwise could be detrimental to not only local residents but the wider District too. RDC should be supporting farmers wherever possible to continue to grow their crops in the district and protect suitable farm land in the area. We do not want to lose the local producers

Q66. Do you agree that our rural communities do not
require individual vision statements? Are there
communities that you feel should have their own
vision? [Please state reasoning]
At this time – yes, but we feel they should have some consideration in the future, in order to protect
them. It would be for the communities to decide their vision statements and we would be happy to
support them.
Q67. Do you agree with our vision for our rural
communities? Is there anything you feel is missing?
[Please state reasoning]
Yes.
Q68. Are there other courses of action the Council could
take to improve the completeness of our rural
communities?
Listen to the residents to see where they would like to go next. See if they require anything specific; travel links, facilities, affordable housing and so on. Empower Parish and Town Councils to take
relevant local actions

EXECUTIVE SUMMARY.
GROWTH SOUTH EAST OF ROCHFORD & NORTH OF SOUTHEND.

Bellway Strategic and Cogent Land LLP, on behalf of the landowners, welcomes the identification of growth
on land South East of Rochford and North of Southend (Strategy Option 3b) in the Rochford District Council
(RDC) New Local Plan: Spatial Options Consultation Paper 2021. The delivery of this growth option will
unlock a new generation of highly sustainable communities that meet housing, employment and qualityof-life needs, while promoting innovation. Bellway Strategic, have acquired the subject landholding from
Cogent Land, and are committed to working collaboratively with the Council, key stakeholders and the
existing community to create an exemplar new community which sets the benchmark for development in
the region and for future generations.
Option 3b should be the priority location for strategic growth within the emerging Local Plan and is
fundamental in delivering RDC’s strategic priorities. This proposal will deliver the step change RDC is looking for to address the housing crisis in the District, along with ensuring the District keeps apace with the Thames Estuary objectives reinforced through the South Essex authorities partnership. Critical to this change in approach is delivering large scale strategic concentrated development in one location and moving away from solely ‘bolt-on’ schemes that fail to deliver the much-needed infrastructure and the benefits for the existing community. This aligns with the Framework which
identifies that in delivering large numbers of new homes significant urban extensions are preferrable
provided they are well located and supported by the necessary infrastructure (including a genuine choice of transport modes). Through existing characteristics in terms of the site’s location on the edge of Rochford and adjacent to Southend Airport, along with proposed infrastructure enhancements, the proposal will satisfy the Framework in this regard crucially ensuring that people have the choice to walk, cycle and access reliable and frequent public transport.
RDC need to find a solution to deliver housing in the short term, in addition to planning for the medium- and long-term. In terms of developing balanced growth across the Plan period, our client endorses Strategy Option 4: Balanced Combination - supporting the delivery of a blend of sites which will ensure the Council can meet their identified housing needs across the Plan period. The preferred strategy will involve making best use of urban capacity (Option 1), building the identified growth option on land south east of Rochford and north of Southend (Option 3b) and a number of smaller urban
extensions (Option 2).
The Council’s previous engagement with local communities has identified the need for improvements
to services and utilities, supporting local employment opportunities, development of sustainable transport options, and improvements to strategic infrastructure as key community concerns. Option 3b will deliver a range of major new infrastructure, including highways improvements, investment in community infrastructure including schools, health centres, the eastern extent of the South Essex Estuary Park, along with sporting facilities and will provide substantial investment in the public realm.
This proposal has the potential to enhance and diversify employment and business opportunities in the local area, enabled by access to high-speed broadband. The scale of development and variety of uses presents opportunities to coordinate energy generation, and to achieve net-zero carbon.

Strategy Option 3b – South East of Rochford & North of Southend will deliver:
Sustainable Communities
New villages within Rochford which respond to the landscape and the morphology of existing settlements

New Homes for Rochford
4,600 homes in total, with 1,850 homes by 2040

Meeting Local Affordable Housing Needs
Deliver c. 650 affordable homes by 2040 (35%) and 1,600 affordable homes in total

Strategic infrastructure improvements delivered alongside growth
Improved eastern access to London Southend
Airport Rail Station, Temple Farm and Purdeys
Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and Warners Bridge.

Job Creation & Employment Land
Deliver c. 11 ha of employment land concentrated in close proximity to existing employment to the south east of Rochford / Southend Airport; together with enhanced
digital connectivity to support home working

Benefits for Existing Residents
Enhanced transport and social linkages to existing villages in Rochford

Genuine choice of transport modes
New green, sustainable transport corridors providing a link between the two train lines (Southend Airport and Thorpe Bay)
Encourage cycling and walking by designing 15-minute neighbourhoods and ensuring high-quality cycle networks to serve existing and future communities.

Community Infrastructure
Delivery of two new primary schools, healthcare and community services in the Local Plan period;

Green & Blue Infrastructure
Utilising the unique natural assets for the benefit of existing and future residents including delivering the eastern extent of the South Essex Estuary Park forming a new coastal country park in the east of the District

Environmental Benefits
Retention and enhancement of historic woodlands and the identification of locations for new woodland for greater biodiversity and wildlife, rewilding, green infrastructure corridors, private food growing and vertical
farming will add to the Biodiversity Net Gain

Tourism Strategy
Harness the untapped potential of Rochford as a tourism destination

Climate Change
Be carbon neutral by 2040 and achieve netzero carbon emissions by 2050 through a host of measures including building design and specifications and encouraging growth of active travel

01. INTRODUCTION & SITE CONTEXT
1.1. Iceni Projects on behalf of Bellway Strategic and Cogent Land wish to submit representations to the Rochford District Council New Local Plan: Spatial Options Consultation Paper 2021. Bellway has acquired an interest in land south east of Rochford / north of Southend and is actively engaged with key stakeholders to bring forward growth in this location, incorporating a mix of uses including housing, community, health and employment uses through the plan-making process. Cogent Land have been promoting the subject site for sustainable growth for almost two decades and wholly support the preparation of the new Rochford Local Plan.
1.2. Bellway Homes is one of the UK’s leading home builders. Bellway began as a small family business in
1946 - with a passion for building exceptional quality homes in carefully selected locations, inspired by the needs of real families. Bellway has grown from a local family firm into one of the country’s leading residential developers. Bellway have this year been awarded 5 star builder status by the Home Builders Federation for the fifth year running.
1.3. The designs of Bellway homes and construction techniques blend tradition with innovation, creating
well-built homes with modern living standards. With a reputation for high quality developments in prime locations, Bellway Homes strive to create sustainable new developments. The homes are designed with more than seven decades of experience and craftmanship, to create a new generation of properties that meets the aspirations of today’s homebuyers. Bellway homes
feature exterior finishes that reflect the character of the local neighbourhood with an enhanced specification, both inside and out.
1.4. The extent of the land under the control of our client within the RDC boundary is detailed in Appendix 1. The landholding lies to the north of the A13 and A1159, with London Southend Airport & Rail Station and Sutton Road sitting to the west. Temple Farm and Purdeys Way employment area, as well as employment opportunities associated with the Airport, are closeby. The River Roach lies to the north and is designated as a Site of Special Scientific Interest, a Special Area of Conservation and Special Protection Area.
1.5. In addition, our client has interests on adjoining land to south which falls within the Southendon-Sea Borough Council boundary. Given that the landholding straddles both Council boundaries the conceptual design studies undertaken to date have considered the land holistically, as many of the Council’s evidence base documents have also done. In this respect, these representations should be read alongside the Potential Growth Options in Rochford and Southend, Proof of Concept, 22.07.2021 attached at Appendix 2. Nonetheless for the purposes of this Local Plan and ensuring the Rochford Local Plan can be found sound in its own right, these representations
focus on the land within Rochford and the proposals that can be delivered within this Local Plan.
1.6. These representations will demonstrate that Bellway, and their appointed consultant team, have prepared a vision for this location to deliver positive growth for the District which will be sensitively designed to connect with the surroundings, will foster social and economic relations with the existing communities, will contribute towards biodiversity net gain, minimising carbon
emissions and protect the environment.
1.7. These representations are structured as follows:
ƒ Section 2 details the main policies contained within the National Planning Policy Framework including the support for large scale growth options and the required approach for plan making in releasing land from the Green Belt;
ƒ Section 3 summarises regional matters in respect of the Association of South Essex Local Authorities, the preparation of a Joint Strategic Plan and the Thames Estuary Growth Commission;
ƒ Section 4 assesses RDC’s housing and employment needs;
ƒ Section 5 considers the strategic matters in Local Plan making;
ƒ Section 6 details the key findings from the RDC landscape impact and green belt evidence base;
ƒ Section 7 sets out the vision for land south east of Rochford and north of Southend;
ƒ Section 8 provides a response to the relevant questions raised in the consultation; &
ƒ Section 9 in conclusion details the economic benefits of Option 3b to Rochford District.

02. NATIONAL PLANNING POLICY FRAMEWORK
2.1. The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to Option 3b.
PLAN LED APPROACH
2.2. The National Planning Policy Framework states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
ƒ meet the development needs of their area;
ƒ align growth and infrastructure;
ƒ improve the environment;
ƒ mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
2.3. This element of the Framework and specifically how the proposal at South East of Rochford and North of Southend will assist the Council in delivering a sustainable pattern of development is considered in detail at Section 5 of these representations.
2.4. Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and enhancement of the natural, built and historic environment. These policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to
address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
LARGE SCALE GROWTH
2.5. The most recent revisions to the Framework include the requirement:
‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’.
2.6. This is applicable in respect of the current proposal at Option 3b and is detailed in full at Section 7 of these representations.
2.7. The Framework at para 73 considers that

“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Working with the
support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way”. (Our emphasis)

This is key in Rochford as acknowledged in the Spatial Options Consultation, that the only way to deliver the Council’s strategic objectives such as addressing current infrastructure deficits is through large scale growth. Growth of a strategic scale will ensure that the housing numbers are delivered but also that the necessary infrastructure, including transport, is delivered alongside
the new homes.
2.9. The Framework advocates that in identifying suitable locations for such development, strategic policy-making authorities should consider a host of factors which are detailed in the table below, alongside a review of the relevant features of growth at South East of Rochford and North of Southend. The policy requirements set out in para 73 of the Framework provide the basis for
assessing the potential and suitability of growth in south east of Rochford and north of Southend.

[See attached document for table format]
Table 2.1 Review of Spatial Option 3b against the criteria set out in Para 73 of the Framework
Para 73 NPPF – Criteria for Large Scale Growth
[followed by] Assessment of Growth Option – South East of Rochford and North of Southend
a) consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains

The site’s location on the edge of Rochford and Southend, and adjacent to Southend airport offers a
major opportunity for inward investment which can
be maximised through growth in the right locations.
At a regional level, Rochford’s location within the
Thames Estuary Growth Corridor, along with the
proximity to London and the Lower Thames Crossing
makes this area an economically competitive area
attractive to inward investment. The development
of this region is a national priority as reaffirmed in
the Government’s Response to the Thames Estuary
Growth Commission.
Moreover, planning for growth at scale will leverage
investment in order to deliver new and upgrade
existing infrastructure in the district. Given the extent of land under the control of Bellway it is considered that significant environmental enhancements can be achieved.

b) ensure that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access;
The proposals provide for four distinct neighbourhoods which are specifically designed to be of a scale so that they are self-sufficient in terms of local services centred on the principle of 15-minute neighbourhoods. There is a swathe of land close to the airport and the existing industrial estates identified for employment uses, and in
addition each neighbourhood will include local employment.

c) set clear expectations for the quality of the places to be created and how this can be maintained (such as by following Garden City principles); and ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed
and beautiful homes to meet the needs of different groups in the community;
Design is key in order to deliver upon the vision of
creating high quality aspirational housing which benefits from the unique location of the site. The Growth Option 3b will be based upon a holistic masterplan framework which establishes a range of different character areas and is genuinely landscape led.
The proposal will deliver a range of housing to achieve diversification in accordance with the recommendations of the Letwin Review including:
ƒ Differing Tenures - Affordable homes; including
affordable rented housing will be provided alongside affordable home ownership on each phase.
ƒ House type and size – Within each phase a broad
range of house types and sizes will be delivered.
ƒ Housing for specified groups and custom build – older people’s housing and plots sold for custom or self-build for individuals on Rochford’s self-build register will also be delivered. Student accommodation will also be explored.

d) make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development
corporations)
The footnote (37) linked to this policy states ‘The
delivery of large scale developments may need to extend beyond an individual plan period, and the associated infrastructure requirements may not be capable of being identified fully at the outset. Anticipated rates of delivery and infrastructure requirements should, therefore, be kept under review and reflected as policies are updated’

The main factor influencing delivery rates will be the
delivery and funding of infrastructure. There are
significant infrastructure requirements needed in order to deliver growth in the District which will have implications on the housing delivery rates. Bellway are keen to collaborate further with the Council in this respect in order to establish the funding and timing of infrastructure which will address existing congestion issues in Rochford and the environs and unlock growth to the east.

e) consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size.

As detailed in the illustrative concept plans, the proposals will be designed based on defensible boundaries, logically defined by the landscape framework

VITALITY OF RURAL COMMUNITIES
2.10. The updated Framework at Para 79 states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.
Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.
2.11. There are a range of existing rural communities in the vicinity of the proposed growth option. The emerging Masterplan and all future proposals will ensure that the character and identity of these existing settlements is retained, while also delivering new infrastructure and services which will be of benefit to the established rural communities. These existing communities do not currently have a genuine choice in terms of travel option, with the private car for many people the only form of transport available. The Local Plan, and the proposals for large scale growth, have the potential to address this through substantial investment in public transport in the district.
2.12. Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could
accommodate some of the identified need for development, as demonstrated through the statement of common ground.
2.13. Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where
exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation recognises that RDC are unlikely to have
sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.

DUTY TO COOPERATE
2.14. The Framework restates that planning authorities are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.
Strategic policy-making authorities should collaborate to identify the relevant strategic matters which they need to address in their plans. Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively
prepared and justified strategy. It is evident that there has been close collaboration between RDC and SSBC in the preparation of the evidence base supporting the Local Plans to date which is welcomed.
2.15. In particular, joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. In order to demonstrate effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.
2.16. The Framework at para 128 requires Planning Authorities to prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality
standard of design.
2.17. National policy in respect of design has been detailed further at Para 129 of the Framework which
states that:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these
exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop”.
2.18. The requirement for design codes is considered at Section 8 of these representations.

03. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.

INTRODUCTION
3.1. The Association of South Essex Local Authorities entered into a Memorandum of Understanding (January 2018) setting out their commitment to build on the existing strong foundations of cooperation developed through the Duty to Cooperate, and within the wider context of the South Essex 2050 Ambition to move to a more formal approach to strategic planning. This will
be developed through a ‘portfolio’ of plans, with a Joint Strategic Plan (JSP) setting out strategic spatial and infrastructure priorities that are of mutual benefit, prepared alongside a suite of ‘local delivery plans’ to manage delivery within each of the local planning areas. As detailed at Figure 6 of the RDC Spatial Options Consultation, the South Essex Plan is a non-statutory Framework which sits above the Rochford Local Plan.
3.2. The JSP will provide the ‘effective strategic planning mechanism’ to ensure compliance with the requirements of the Duty to Cooperate, with the existing joint work, evidence base and shared governance through ASELA demonstrating that cooperation is proactive, positive and ongoing.
There is a clear commitment to meeting the full housing needs across the sub-region. ASELA have confirmed that they are committed to work collectively in the interests of South Essex detailing that the “joint spatial plan will provide a strong framework to build on and deliver the sound individual local plans and provide the future strategic context for them”.
3.3. The ASELA Productivity Strategy provides a framework for addressing some of the challenges
across the region, outlining that the future of work is changing and higher-skilled, knowledgebased work will drive future economic activity. It sets out opportunities to attract, retain and develop highly skilled knowledge workers, including through skills development; encourages B2B collaboration and development of local supply chains; and identifies opportunities to use data and leverage connectivity to grow the economy through both growth of indigenous SME businesses and attracting inward investment. It emphasises the importance of town centres as centres for economic activity which offer a rich social experience and space for interaction and can accommodate a range of economic activities.
SOUTH EAST ESSEX STRATEGIC GROWTH LOCATIONS ASSESSMENT 2019
3.4. RDC, SSBC and Castle Point Borough Council (CPBC) have worked together to consider potential spatial options for future strategic scale residential development, jobs and supporting infrastructure. The South East Essex Strategic Growth Locations Assessment has considered and assessed six broad locations of undeveloped land adjoining the built-up area of Southend and considered their potential to accommodate strategic scale development of approximately 6,000 – 8,000 homes, together with employment and supporting infrastructure. The report
considered six broad locations, Sectors A-F and identified that only Sector D has the potential to
accommodate strategic scale development. Option 3 b sits within the Sector D area.
3.5. The Plan’s evidence thus identifies Sector D – land north of Fossetts Farm, Garon Park and Bournes Green Chase - as the only area in Rochford which adjoins Southend’s urban area which offered the potential for strategic scale development. This area was found to have the least environmental constraints. The landscape was found to be of medium sensitivity, and development
would need to have regard to this as well as listed buildings and heritage assets in the area.
3.6. The Assessment found that significant investment in public transport, road and cycling infrastructure would be needed to support sustainable development. This included congestion concerns along the A127 and at Warners Bridge. It found synergies with nearby employment locations and existing recreational resources including around Garons Park. Major development would need to avoid coalescence with Rochford and maintain a buffer to the villages of Barling, Little Wakering and Great Wakering to the east.

SOUTH ESSEX STRATEGIC GROWTH LOCATIONS STUDY 2020
3.7. The 2020 South Essex Strategic Growth Locations Study1 reinforces the findings of the 2019 study, which has undertaken a strategic review of land availability and development constraints across South Essex and considered potential locations where urban extensions and new settlement-scale growth could be explored. This Study has assessed the potential for urban extensions to each of the District’s main settlements - Hockley, Rayleigh and Rochford – as well as Southend; together with the potential for new-settlement scale growth north-east of Southend and at Fairglen where the A127, A13 and A130 join.
3.8. The Study shows that transport infrastructure capacity is a particular constraint to growth at a sub-regional level with a highways network largely at capacity at peak times. An appropriate response to this is to locate growth at accessible locations, preferably where there is fixed public transport and this is a key component of the ‘sequential approach’ adopted in the Study to identifying potential locations for strategic scale growth. The Study includes an assessment of the relative accessibility of different options, having regard to proximity to major routes and local congestion; and public transport accessibility. Hockley scores poorly, and Rayleigh is moderate in this respect; while Rochford and Southend together with the potential for strategic growth south east of Rochford are identified as having good accessibility. Fairglen is identified as having very poor accessibility by public transport currently and would require delivery of a new station to support strategic development.
3.9. The Study concludes that the best scope in the medium term is for strategic growth at Southend North East and West Horndon. This reflects the less constrained nature of these locations relative to other areas considered and the greater potential for sustainable access even in the short to medium term. This issue of sustainable access is critical given the constrained nature of the existing highway network in South Essex and the fact that strategic growth must have viable non-car access. There are however still significant challenges in these locations, including the requirement for substantial supporting infrastructure and further studies are required.

GOVERNMENT RESPONSE TO THE THAMES ESTUARY 2050 GROWTH COMMISSION 2019
3.10. In the Budget 2016 the Government asked the Thames Estuary 2050 Growth Commission to set out an ambitious vision and delivery plan for North Kent, South Essex and East London. The Thames Estuary 2050 Growth Commission published their report on 25th June 2018. In the response published on the 25th March 2019, the government welcomed the Commission’s vision, and sets out national commitments to the Thames Estuary.
3.11. The government’s response is a clear demonstration of the commitment to growth in the Thames Estuary and identifies that this is a national priority which is of importance to all of the United
Kingdom. The response acknowledges the tremendous potential of the Thames Estuary to power growth for the benefit of local communities and the entire country. It highlights however that the region does not fully deliver on its great potential and “A bolder approach is needed to realise this vision and the potential of the region”.
3.12. In addition, the Government agrees with the Commission that the scale and pace of delivery will need to increase to meet demand for housing across the Estuary. The report further states that the Government is prepared to offer bespoke support through initiatives such as housing deals, to support those places willing to be ambitious in their approach to building more homes.
Government would expect places across the region might want to go further in order to take account of higher demand and fully enable them to meet their economic growth ambitions.
3.13. This report wholeheartedly confirms the Government’s commitment to this region. The Local
Plan has the opportunity to utilise this support from a national level to ensure that the region fulfils its full potential in terms of new homes and jobs through a plan-led approach. This is an unprecedented opportunity for the region and RDC must capitalise on this to ensure they fulfil their ambitions.
3.14. Rochford is located within the South Essex Foreshore, and within this context the Commission’s
vision for the area is :
“The rich patchwork of places which form the South Essex Foreshore will be celebrated. Empowered by a statutory Joint Spatial Plan the area will go beyond ‘business as usual’. Locally driven town centre transformation will help create lively places that people choose to work, live, learn and play in. These policies and local initiatives will see development unlocked, postindustrial landscapes restored, and the filling of empty business spaces to create a thriving and
creative economy”.
3.15. This vision aligns with the positive approach outlined in the RDC Spatial Options which states that “The scale of housing growth required in Rochford presents opportunities to do things very differently and harness much greater investment in infrastructure than has been possible before”

04. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.
Current Situation
4.1. In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2. The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
Future Housing Needs & Supply
4.3. Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040 in RDC. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in
10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4. The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. The emerging evidence provides a strong indication that SSBC will not be able to meet its development needs for housing and employment in full within its borough boundaries.
Southend has a constrained supply of land which also limits its ability to deliver family housing.
Given the close-relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services between the two authorities, the Council needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5. Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.

[SEE ATTACHED DOCUMENT FOR ORIGINAL DIAGRAM OF ROCHFORD HOUSING CRISIS]
- Average house price in Rochford 2021: £426,000 (12% increase since 2020)
- House price growth 2011-21: £136,000
- House prices 11.5 times average earnings. Amongst the least affordable areas in the country
- Average rents grown 18% over last 5 years
- 1,000 households awaiting affordable housing in 2021 (grown by 20%)
- Average housing delivery 205 dwellings per annum (2011 – 2021)

4.6. In this respect, the Planning Practice Guidance provides clarification on the standard method
reiterating that it provides the minimum starting point and details the circumstances actual housing need is higher than the standard method indicates, stating:
Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in
place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.
3.7. Set against this, the Council’s Housing and Employment Land Availability Assessment considers
the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,500 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short
of the District’s housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
[SEE ATTACHED DOCUMENT FOR TABLE COMPARING LAND SUPPLY TO HOUSING NEED]

4.8. Available and suitable land for housing in Rochford is scarce, with the majority of open land being
designated as Metropolitan Green Belt, extending from London across the South Essex subregion. Significant parts of the District are also protected for their ecological value, landscape value or because they are at risk of flooding.

ECONOMY
4.9. As with many other areas across the country and internationally, Rochford’s economy has been harmed by the Covid-19 pandemic. The Local Plan needs to set out a strategy for economic recovery.
4.10. Prior to the pandemic, the evidence pointed to :
ƒ a relatively modest-sized economy with 29,000 workforce jobs based in the District (2018).
ƒ The percentage of jobs available per resident is much lower than the national average, leading to a greater reliance on out-commuting for our residents and leakage of spending and investment
ƒ Significant out-commuting of residents to work, totalling over 14,000 people per day in net terms, both to surrounding employment centres such as Southend and Basildon and to London.
ƒ Self-employment had been growing, reaching almost 16% of working-age residents.
ƒ Local employment opportunities were focused more towards lower paid/skilled roles, with the proportion of residents with NVQ 4+ skills (equivalent to degree level) below the regional average, and an under-representation in higher value-added sectors borne out in average earnings for those employed in the District which were around 7% below the East of England average.
OFFICE AND INDUSTRIAL ACTIVITIES
4.11. The 2017 South Essex Economic Development Needs Assessment (EDNA) identified a need for 27 ha of employment land across Southend and Rochford to 2036. Quantitatively it identified sufficient supply to meet this. The evidence base will need to be updated to reflect changes in economic circumstances and the longer plan period. However it is likely that some additional
employment land provision is needed in the local area to support growth in local SME businesses in manufacturing, construction, trades and related sectors including in providing grow-on space; and to contribute to addressing the significant out-commuting from the District. National planning policy and guidance is clear that both quantitative and qualitative factors should be
considered in considering employment land provision.
4.12. The Covid-19 pandemic and associated lockdowns have ushered an unprecedented change in the way people work, almost overnight. The Local Plan needs to facilitate these changes by providing opportunities to work more locally for those that might have historically commuted out to work, and ensuring high quality broadband infrastructure is in place.

[See document for original diagram re benefits of meeting housing need]
- Delivering affordable housing
- Family housing for local people
-Supporting the local economy
- Supporting funding and delivery of infrastructure
- Supporting town centres
- Supporting public services

RETAIL AND LEISURE
4.13. Rochford District’s main retail provision is within the centres of Rayleigh, Rochford and Hockley.
However, none of these are major classified centres and Rochford achieves a very low market share of retail provision in comparison to the rest of South Essex. In particular, retail expenditure for comparison goods is generally lower in the District than it is for convenience goods, demonstrating that residents will often do their regular shopping (such as food) more locally but travel to other commercial centres, such as Southend, for comparison retail shopping such as for household items, electrical goods and clothes.
4.14. The Retail and Leisure Study Update 2014 recommended that the District seek to increase the
market share of comparison retail to a minimum maintain market share in South Essex. The South Essex Retail Study 2017 sets out that the District would benefit from further retail provision to promote sustainable shopping patterns, with retail provision aligned new housing growth.

E-commerce had been growing before the pandemic, but Covid-19 is likely to have accelerated this, and this is a particular challenge for the District’s town centres which therefore need to evolve. Housing growth within the District together with an evolution of the town centres’ offer will be important to supporting the vitality and viability of the District’s town centres.
TOURIST ECONOMY
4.15. The tourism economy in Rochford District is currently underdeveloped – there is a lack of infrastructure such as quality accommodation, restaurants and cafes, visitor attractions and activities. The District has a distinctive character – it benefits from a world-class natural environment with internationally significant estuaries, namely the Crouch and Roach and an extensive coastline, including the RSPB’s Wallasea Island Wild Coast Project. These geographical features give rise to the potential to explore opportunities to promote tourism, particularly a green tourism offer. Rochford also has a range of heritage assets with untapped potential.
4.16. The Tourism, Leisure and Recreation Strategy for South Essex 2020-2038 sets a vision “to make South Essex a renowned major tourism destination comprising a corridor of quality interrelated tourism, leisure and recreation attractions. An expanded visitor offer will
encourage people to stay and enjoy our culture, resorts, countryside, market towns and coastline. In turn this will add to the area’s vibrancy and make us a more attractive place to live, work and start up a business”.
4.17. It identifies that there are some structural weaknesses that exist, such as the lack of a ‘stand out’
single attractions. A key conclusion that is drawn is that there is a number of exciting and attainable opportunities which can be the focus of future strategic action. This would help the area to bounce back from Covid-19 and reposition the area in the domestic visitor market.
4.18. There is a clear opportunity for the District to increase the value of the tourism economy over the
Local Plan period in the following ways:
ƒ increasing visitor spending by providing high-quality facilities and attractions and supporting infrastructure;
ƒ increasing the number of linked trips to Southend and other locations in South Essex;
ƒ converting a proportion of day trippers into overnight stays;
ƒ increasing the share of holiday makers as opposed to people visiting friends and relatives;
ƒ Capitalising on the ‘staycation’ market;
ƒ capturing the untapped potential of the district’s assets, including the historic environment, the countryside and coast; and
ƒ developing the business tourism offer and overseas visitors to capture this higher value market segment linked to London Southend Airport.
4.19. The Tourism, Leisure and Recreation Strategy for South Essex outlines objectives to provide a planning framework to facilitate development, including co-ordinating the development of appropriate Local Plans that support the development of tourism, leisure and recreation. The preparation of the Rochford Local Plan provides an appropriate basis for achieving this.

ECONOMIC POTENTIAL OF OPTION 3B
4.20. Our economic analysis points to the following opportunities:
ƒ The local economy across Southend and Rochford is structured around the delivery of goods and services to local people and visitors. The economic strategy for the Option 3b will tie into this, and deliver job opportunities in everyday services, health and education on site, but also recognise and encourage spending from residents on shops and services in Rochford Town Centre.
ƒ Southend Airport is also an important local employment driver in the medium-to-long term,
with potential growth of both direct jobs on site and in the supply chain and aviation-related activities in the surrounding area. There is a good spatial relationship to this.
ƒ The scale of the development opportunity provides an opportunity for transformational change and can act as a major economic driver in its own right. The scheme will support sizeable population growth creating demand for goods and services within the local economy. It can
deliver employment in traditional employment space, support home-based working, and create/support employment opportunities in health, education and local services.
ƒ If the scale of development is comprehensively considered, there is a strategic opportunity to shift the skills and jobs profile towards higher value-added activities. Delivery of high-quality housing, with space to work, and better employment opportunities have the ability to attract higher paid/ earning individuals to avail of the benefits of coastal life.
ƒ Self-employment in the area is high and has been growing. There are many small business and self-employed enterprises in the area. The office market is focused on local SME occupiers.
Local centres within the scheme should be designed in a way in which they can accommodate flexible workspace in local work hubs which can cater for local micro-businesses, can provide workspaces for people that might commute into London less or who work principally at/ hear home. Provision of high-quality broadband and telecommunications infrastructure will also be key to supporting this and facilitating the growing trend in home working. As working patterns change as a result of Covid and technological improvements, there is a major opportunity to create an attractive residential environment with local workspace which responds to this.
ƒ There is a concentration of industrial space in the area with low current vacancy levels. There is a strong relationship between the site and existing key employment and industrial sites in the local area, including Purdeys Industrial Estate, Temple Farm, Stock Road, Rochford Business Park and the Airport Business Park. There are opportunities to deliver high quality connections to these.
ƒ The development offers potential to help diversify the area’s visitor / tourism offer and to increase tourism spend, including in exploring the potential of the River Roach, provision of a high-quality hotel and/or visitor resort offer.
ƒ There is a good opportunity to deliver different types of housing, including: family housing both market and affordable, specialist/ embryonic sectors, Build to Rent, third age living including a range of care products and the self-build sector. Diversity in the housing offer, and recognition of the relative role of growth here vis-à-vis what is delivered within the urban area (focused more on higher density / smaller units), is important to supporting overall housing delivery rates, a balanced population profile and attracting higher skilled/ earning households.

05. STRATEGIC MATTERS IN LOCAL PLAN MAKING.
5.1. The Framework at para 11 requires Plans to apply a presumption in favour of sustainable development.
For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
1. meet the development needs of their area;
2. align growth and infrastructure;
3. improve the environment;
4. mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
5.2. This section of the representations considers these strategic matters in a Rochford context and considers how growth on land south east of Rochford and north of Southend will assist RDC in delivering a sustainable pattern of development.
MEETING THE DEVELOPMENT NEEDS OF THEIR AREA
5.3. RDC propose to take a positive approach to growth locally, help to create a more inclusive housing market, avoiding the emergence of housing-related issues including homelessness and concealed households. A number of strategy options have been identified that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
5.4. These representations wholly endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend which lies within our client’s land interests. It is not purported however that this strategy will meet Rochford’s full housing need over the lifetime of the Plan, thus Strategy Option 4: Balanced Combination is the preferred approach. The Consultation states that
Option 4 could make best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2).We support Option 4 which will provide a varied supply of sites to make the local housing market as diverse as possible delivering a range of choice and competition to the market, thus offering the greatest chance that housing will be consistently delivered over the whole plan period. Crucially the Plan needs to incorporate large scale strategic growth, as a Local Plan strategy that relies solely on smaller sites, or sites spread more evenly through the District will not have the potential to fund new infrastructure and provide betterment to the current challenges facing the District.
5.5. It is submitted that in order to deliver the ambitions of the Local Plan, large scale growth focused in one location as per Option 3b is required. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic Growth Locations Study (2020).
5.6. Option 3 b is the only option which will:
ƒ Provide the “critical mass” needed to secure transformational new infrastructure to mitigate the impact of future development and critically to address the chronic congestion currently experienced within the District
ƒ improve affordability
ƒ address the decline in home ownership
ƒ support a sustainable shift towards higher wage/skilled jobs.
5.7. The Government have also been clear in their funding decisions that they will help fund infrastructure
where it is supporting their growth ambitions. Option 3b will make a substantive positive contribution to the Government’s ambitions for growth across the Thames Estuary Area. The Government’s Response to the Thames Estuary Growth Commission (HM Government, March 2019) states that it will support regeneration and growth within the area through a range of measures, including negotiating Housing and Infrastructure Deals with groups of ambitious local authorities. Option 3b provides the greatest potential to capture funding through such deals.
ALIGN GROWTH AND INFRASTRUCTURE
5.8. The Council’s previous engagement with local communities has identified the need for improvements to services and utilities, supporting local employment opportunities, development sustainable transport options, and improvements to strategic infrastructure as key community concerns alongside concerns regarding the number of homes. Strategic growth provides an
opportunity to address these issues. The vision for land south east of Rochford and north of Southend is that the development brings positive benefits to all residents including through the delivery of new infrastructure for sport, recreation and leisure; the provision of new high quality employment opportunities; and in supporting the delivery of strategic transport infrastructure which helps to improve accessibility across the area including addressing existing congestion bottlenecks in Southend and Rochford and delivering new high quality public transport links and opportunities for walking and cycling.
5.9. The Planning Practice Guidance requires Authorities in Plan-making to set out a positive vision for the area, but the plan should also be realistic about what can be achieved and when. This means paying careful attention to providing an adequate supply of land, identifying what infrastructure is required and how it can be funded and brought forward. A collaborative approach is expected to
be taken to identifying infrastructure deficits and requirements, and opportunities for addressing
them. In doing so they will need to:
assess the quality and capacity of infrastructure, and its ability to meet forecast demands.
Where deficiencies are identified, policies should set out how those deficiencies will be addressed; and
ƒ take account of the need for strategic infrastructure, including nationally significant infrastructure, within their areas.
5.10. The government recommends that when preparing a plan strategic policy-making authorities use available evidence of infrastructure requirements to prepare an Infrastructure Funding Statement. Where plans are looking to plan for longer term growth such as significant extensions to existing villages and towns, it is recognised that there may not be certainty and/or the funding secured for necessary strategic infrastructure at the time the plan is produced. In these circumstances strategic policy-making authorities will be expected to demonstrate that there is a reasonable prospect that the proposals can be developed within the timescales envisaged.
Our client is keen to work with the Council and their appointed consultants in respect of the infrastructure requirements for growth Option 3b to accommodate future growth, and crucially ensuring betterment for the existing residents in the district.
Genuine choice of transport modes
5.11. Rochford’s peninsula location creates issues for connectivity with relatively limited sustainable travel options available, particularly north-south, leading to notable congestion along key roads. Given the existing level of traffic within the District and how this affects the road network, future strategic highway decisions and plans must consider how changes in working habits and future technology can help promote innovative but realistic transport solutions.
5.12. It is essential that public transport connections to the stations and key employment locations in the sub-region are improved to provide realistic and viable option to residents from commuting and other journeys. This can help reduce congestion. In addition, whilst there are a number of existing cycle routes within the District, these routes are often found in isolation. Whilst there are routes along Ashingdon Road, Hall Road and Cherry Orchard Way, these are not continuous. Future investment should look to ensure integration and improvement of existing cycle routes where possible and ensure cycling is considered as a key mode of travel from the outset.
5.13. The District cannot however be considered in isolation and the continued expansion of development in the adjoining Southend Borough has led to an increased propensity for vehicles to find alternative routes to the A127 (A1159), often resulting in growing pressures on Rochford’s own network. The Authorities will need to work collaboratively to address these issues - ensuring
unnecessary trips on the network are removed and essential trips are accommodated along appropriate existing or new infrastructure.
5.14. The concept of ’15 minute neighbourhoods’ can help to achieve this. These are based on ensuring that residents to access the majority of their day-to-day needs – such as everyday shops, schools, medical facilities, pubs, cafes and leisure opportunities - within a 15-minute walk or cycle. This has been shown to build sustainable communities and reduce private car use throughout the world.
5.15. Future communities proposed on land south east of Rochford and north of Southend will be designed to encourage cycling and walking by promoting 15-minute neighbourhoods and ensuring high-quality cycle networks are provided to link up with both existing communities’ and other future communities. This integration is key to help promote active travel. For locations and routes where high levels of cycle use are expected, green corridors for example, we will look to promote segregated spaces for other cyclists and pedestrians to ensure safety and encourage active travel.
5.16. Consideration will also be given to how other forms of powered micro-mobility can be promoted such as, e-scooters or powered skateboards. The Council is keen to lead the way with new technological solutions and ensure developments have electric charging for not only for
vehicles, but the bicycle, moped and e-scooters. This might include a new e-scooter and e-bike hire scheme in Rochford and Rayleigh which could take the form of autonomous e-scooters, improving the efficiency of their operation.
A New Travel Corridor Network
5.17. A key constraint that is recognised in the transport evidence is that despite the sustainability imperative to reduce car use, local people continue to use their car for short journeys and tolerate the time lost in congestion. It appears there is a general resident’s desire locally to continue using their cars for most journeys and expected new infrastructure that supports it.
5.18. The local network is currently congested. Access by car is broadly restricted geographically to the west along the A13 and A127. Once these routes penetrate the borough boundary, they quickly become congested. This has resulted in rat-running, even for local journeys. Capacity improvements have taken place along the A127 which include improvements to Progress Road, Kent Elms, Tesco roundabout and Cuckoo Corner. Works are currently underway at the Bell House Junction. The distribution of employment zones in the area has contributed to congestion and created a poor environment for pedestrians and cyclists.
5.19. Rochford is formed of a number of towns, villages and standalone employment locations. Improving the east-west connections will not only help those leaving the District as part of their commute but will also ensure that existing businesses within the District are seen as viable
locations for employees.
5.20. It is also important to optimise the opportunities associated with London Southend Airport as an
economic driver and a rail station. It is essential that surface access and access to both the local and strategic highway network is improved. By doing this, the Airport can help support economic growth in both the district and the wider South Essex area. To help achieve this access to the station from the east will be required.
5.21. Strategy Option 3b will deliver strategic infrastructure improvements alongside growth including improved eastern access to London Southend Airport Rail Station, Temple Farm and Purdeys Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and Warners Bridge. Strategic growth will enable the delivery of a new green, sustainable transport corridor providing a link between the two train lines Southend Airport and
Thorpe Bay.
5.22. If strategic growth is delivered between Southend and Rochford, changing the design characteristics of infrastructure from what has previously been provided is key to delivering a solution that fits both travel behaviours now and in the future. Through a forward-thinking
approach we ensure that any hard infrastructure provided in the District cannot only make use of new technologies as they become available but are also not held back by building solely for the problems at the time. For example, in the short term, a green corridor could be formed of a
two-lane dual carriageway. However, as working behaviours move towards a more home-based approach or as more local employment opportunities become available, the need for two-lanes will be reduced. As such, one lane in each direction could be converted to a bus lane.

IMPROVE THE ENVIRONMENT
5.23. In the recently updated Framework, the environmental objective wording has been strengthened
with a requirement to ‘protect and enhance’ the environment and ‘improve biodiversity’. The key issue for consideration is crucially how the proposals will protect and enhance the environment.
5.24. By way of context, over 70% of Rochford is designated Metropolitan Green Belt with over 15%
protected for its biodiversity value. The subject landholding south east of Rochford and north of Southend lies within the Green Belt but is not covered by any statutory environmental designations. The River Roach lies to the north and is designated as a Site of Special Scientific Interest, a Special Area of conservation and Special Protection Area; with land in this northern
part of the area falling within Flood Zones 2 and 3.
South Essex Estuary Park
5.25. The RDC Open Space Study 2020 revealed that the current quantity provision of all open spaces in the District is at 8ha per 1,000 people. This falls below the Fields in Trust benchmark. This provides a further opportunity for the new Local Plan to address this shortfall of which the proposals for the South Essex Estuary Park are integral to.
5.26. The South Essex Strategic Green and Blue Infrastructure Study (2020) was prepared on behalf of
ASELA and sets out a vision for green and blue infrastructure across South Essex and provides high-level objectives, strategic opportunities and policies driven by a co-ordinated approach.
The Study defines an integrated green and blue network, that will provide multiple benefits and which merits prioritisation and significant investment as well as defining a spatial arrangement to create the South Essex Estuary Park (SEE Park) - a network of green and blue assets across the
region. Growth Options 3 b have the potential to deliver the eastern extent of the SEE Park.
5.27. Figure 5.1 extracted from the Green and Blue Infrastructure Study shows indicative opportunities
which could help to deliver a regional green and blue infrastructure resource. Island Wetlands is identified as one of these landscapes, as shown below, which extends from Wallasea Island to Southend. Initiatives around Wallasea Island will create a large wetland nature park, with designated areas accessible to people. The southern part of the park shown - closer to Southend – indicates the potential for the creation of green corridors linking urban areas, the countryside and coast and
providing much needed green open space for existing and future residents. The proposal could contribute towards delivering these ambitions. The ambitions for the green and blue infrastructure need to be aligned with the growth options to maximise the benefits that can arise.
5.28. Figure 5.2 details our interpretation of the ambitions for the parkland and how the strategic blue and green infrastructure will influence the design of the growth option south east of Rochford and north of Southend.
Figure 5.1 Sub-Regional Green and Blue Infrastructure Study – Indicative Opportunities [SEE DOCUMENT FOR MAP]
Biodiversity Net Gain
5.29. The proposals will maximise opportunities to enhance and protect local ecosystems and green
infrastructure will be exploited to achieve a minimum 10% biodiversity net gain. This will ensure that biodiversity is improved across the District through new development, minimising incumbent losses and restoring ecological networks.
Figure 5.2 Indicative proposals for strategic green and blue infrastructure on land east of Rochford and north of Southend [SEE DOCUMENT FOR IMAGE]
MITIGATE CLIMATE CHANGE AND ADAPT TO ITS EFFECTS
Active Travel
5.30. It is no secret that the emissions generated by fossil fuel-based vehicles are contributing climate change. The Local Plan should guide development and investment in the District to supports the Government’s target of reaching net-zero carbon emissions by 2050, as well as the Association of South Essex Local Authorities (ASELA) aim to be carbon neutral by 2040. To help meet these targets, Rochford must show leadership in promoting the use of electric cars and buses to its
residents and encouraging growth of active travel.
5.31. We are also on the brink of a new transport revolution, with numerous technologies coming forward - in both the short, medium and long term - each having their own impact of personal travel options. It is therefore important to consider how travel will change over the plan period. In recent years, many residents have commuted to work 3-5 days a week using a fossil fuel burning vehicle, however, by the end of the plan period, residents might only commute to work twice a week (with a 60% reduction in capacity demand); use electric vehicles, which could in time be self-driving; or make use of a high-quality public transport option. It is clear that the technological and transport solutions to accommodate likely travel behaviours at the start of the plan will not match those at the end of the plan in 2040. Getting this aspect of future development wrong could lead to large roads being built that are far too big for the expected travel patterns at the end of the plan period and we are left with huge barriers, severing communities unnecessarily.
Building Design
5.32. The National Housing Federation states England’s homes produce more carbon emissions every year than all the country’s cars thus decarbonising housing is an urgent priority. At a building level, this means designing buildings with highly efficient building fabric to reduce demand for energy and associated energy bills. Bellway’s homes will aim to be fossil fuel free where possible, using
innovative and renewable forms of energy production and storage to make the most of the UK’s increasingly decarbonised electricity supply.
5.33. Building homes with a ‘fabric first’ approach means high levels of insulation, reduced air permeability and reduced cold bridging, and uses passive design to retain heat within buildings by minimising losses to the outside. This is the basis of the PassivHaus scheme, which has been shown to result in homes with very low levels of energy demand due to good passive design to minimise heat loss. The benefits of this approach to design include low heating bills, reduced risk of obsolescence, not
having to retrofit to improve insulation levels and homes that are futureproof.
5.34. Where appropriate, waste heat from industrial processes can provide heating for new and existing homes, making the most of our existing energy resources. Opportunities to partner with industry to generate renewable electricity at scale on suitable sites across the District will also be explored, meeting wider climate change objectives and providing an income to the Council.
Alternative Fuels
5.35. There are opportunities to make use of sustainable hydrogen, either for building heating or vehicle
transportation. Hydrogen has the potential to partially replace natural gas within our existing gas infrastructure. Although the majority of current hydrogen production methods are not sustainable, the growing levels of renewable electricity in the national grid mix will mean that sustainable hydrogen can be produced more widely in suitable locations throughout the country.
Lifestyle
5.36. New and innovative technology will play its part in helping to decarbonise Rochford. However we also need to help our residents to live more sustainably, by demonstrating that sustainable lifestyles lead to better quality of life. By encouraging people to participate in active travel, walking and cycling where possible, residents will see benefits to their health and wellbeing. Local air quality will be improved. Our roads will be safer. We will get to know our neighbours better.
5.37. Taking account of the District’s rural character, consideration can also be given to the use of land for sustainable food production. This could vary from the provision of allotments by residents to grow their own food to the use of new, innovative farming techniques, such as vertical farming which maximises food production on a smaller footprint.

06. LANDSCAPE & GREEN BELT EVIDENCE BASE.
6.1. In order to meeting minimum housing needs, RDC will need to release land from the Green Belt.
Rationale for Strategic Green Belt Release
The evidence base indicates that Strategic Green Belt release is required through the preparation of Rochford’s Local Plan as:
ƒ Meeting development needs is an important component of achieving sustainable development – the key aim of the planning system. The evidence shows that this cannot be achieved across the sub-region without reviewing Green Belt boundaries. The aim of Green Belt policy is not to restrict meeting development needs. It is to direct development to sustainable locations;
ƒ Green Belt release is required to meet the identified local need for market and affordable housing and improve housing affordability, a key feature of Government policy, as well as to deliver family housing – the need for which is not being met through urban sites in the sub-region;
ƒ Strategic growth is required to support economic recovery and sustainable economic growth – key policy ambitions at a national, sub-regional and local level. It will support growth in the workforce, attract skilled workers and attract higher paid employment
opportunities as identified in the ASELA Productivity Strategy.
ƒ The evidence base identifies key infrastructure deficiencies. Strategic growth will support the funding and delivery of strategic infrastructure including transport infrastructure to promote more sustainable travel and address existing congestion.
ƒ It is appropriate that consideration is given to meeting unmet need from Southend in locations which have a strong spatial and functional relationship to in a context in which there are strategic constraints to development at a sub-regional level.
6.2. The Joint Green Belt Study (February 2020), covering Rochford and Southend, assesses the
performance of Green Belt land in meeting the purposes of Green Belt. The strongest performing Green Belt is land within the Upper Roach Valley between Rayleigh, Thundersley and Southend. Only small areas of land on the urban fringe are identified as having a low performance against Green Belt purposes. These areas of land alone will not provide sufficient land to meet development needs;
indicating a need to consider land with one or two strong ratings against Green Belt purposes.
6.3. The south-eastern part of the Green Belt – adjoining the urban boundary with Southend - has two strong ratings, which is likely a reflection of its purpose to prevent urban spawl. It should not be assumed that a site that weakly contributes to the Green Belt is automatically a good candidate for development, nor that a site which strongly contributes to the Green Belt is automatically a poor candidate for development. In making decisions regarding Green Belt release, performance against
Green Belt purposes however needs to be considered alongside wider factors which influence what
constitutes sustainable development – including access to services and employment opportunities.
The purpose of Green Belt is to support sustainable patterns of development.
Figure 6.1: Green Belt Performance – Southend and Rochford
[see attached document for map]
6.4. The area south-east of Rochford which has been identified as a potential strategic growth location falls into parcels AA153-AA158 of Stage 2 of the Green Belt Study. In most scenarios, these parcels are considered to have a high harm if they were to be released from the Green Belt.
There are however some scenarios where if certain smaller parts of this wider area were released, the harm would be reduced to moderate-high. This would only be the case if these smaller parcels were released in isolation.
6.5. Whilst the ideal would be to minimise harm to the Green Belt, it may be that the most sustainable
locations for development will result in high harm to the Green Belt. Conversely, the release of Green Belt land likely to result in low harm may not be appropriate or sustainable. In each location where alterations to Green Belt boundaries are being considered, planning judgement will be required to establish whether the sustainability benefits of Green Belt release and the associated development outweigh the harm to the Green Belt designation.
ROCHFORD AND SOUTHEND LANDSCAPE CHARACTER, SENSITIVITY AND CAPACITY STUDY (2020)
6.6. The Landscape Character, Sensitivity and Capacity Study prepared for Rochford and Southend sets out the value and sensitivity of landscape character areas in the two LPAs and their potential capacity for development to inform strategies for the area.
6.7. The majority of the land at the strategic growth location Option 3b is within the Coastal Farmland Landscape Character Type, specifically parcel C5 (Stonebridge). The landscape value, sensitivity along with the landscape capacity and recommended development scale are detailed in the table below. The Study identifies that this land parcel had medium to high
capacity for development.
Figure 6.2 Landscape Capacity extracted from the RDC Landscape Character Study
[see attached document for map]

[SEE ATTACHED DOCUMENT FOR TABLES DETAILING LANDSCAPE CHARACTER ATTRIBUTES]

07. THE VISION FOR LAND SOUTH EAST OF ROCHFORD / NORTH OF SOUTHEND.

CONTEXT
7.1. The RDC Spatial Option Consultation identifies a number of strategy options that could form the basis of the plan’s approach to growth over the next 20 years and beyond. These representations endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend.
7.2. As detailed in these representations, Option 3b is required in order to deliver the ambitions of the Local Plan with large scale growth focused in one location which will provide a sufficient critical mass in order to deliver the required infrastructure for the District. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic
Growth Locations Study (2020).
7.3. This location provides the opportunity to deliver strategic development at scale which includes new homes and employment land, new strategic transport infrastructure, local services and associated community facilities and additional open space and recreational facilities. The strategic rationale for growth is to:
ƒ Contribute to meeting the strategic housing need for market and affordable housing in Rochford and also potentially unmet needs from Southend in a location close to where the need arises;
ƒ Locate growth at a sustainable location close to the concentration of existing employment opportunities at and around London Southend Airport, Temple Farm and Purdeys Industrial Estates, Fossets Way and Gardon Park, to reduce the need to travel and achieve a high
proportion of travel by sustainable modes;
ƒ Provide strategic scale development where housing can be brought forward alongside local employment opportunities, schools, healthcare facilities, local shops and services in line with the principles of 15 minute neighbourhoods in order to reduce the need to travel;
ƒ Deliver concentrated strategic growth which reduces the scale of incremental growth of the District’s existing towns and villages which can place pressure on their local infrastructure and adversely affect their character;
ƒ Enable strategic infrastructure improvements alongside growth including improved eastern access to London Southend Airport Rail Station, Temple Farm and Purdeys Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and
Warners Bridge.
Figure 7.1: Land South East of Rochford & North of Southend Broad Location for Growth
[SEE ATTACHED DOCUMENT]
THE VISION
7.4. There are a number of themes which have informed the vision for the subject site -
ƒ A sequence of new neighbourhoods – the proposals include four individual, future facing neighbourhoods in Rochford, which contain mixed-use neighbourhood centres and the key community infrastructure and services required to support residents needs and reduce the need to travel, that can be brought forward alongside one another with a distinct identity and character. The character of these neighbourhoods can vary and respond to their location – with new hamlets and villages within Rochford which respond to the morphology of settlements in the area.
ƒ A Connected Place – the neighbourhoods will be physically connected by new green, sustainable transport corridors which also provides a link between the two train lines (Southend Airport and Thorpe Bay) and encourage sustainable transport choices. Proposed infrastructure will also help redress existing capacity constraints on the highways network.
Digital infrastructure is also at the forefront of the strategy to deliver connectivity. The proposals will help to deliver new strategic infrastructure which addresses existing congestion issues along the A127 and A1159 Eastern Avenue;
ƒ A Place with Identity – the proposals seek to identify and establish a character that draws from that of the surrounding context and is informed the existing site features. This involves drawing out local character and distinctive features associated with the area. .
ƒ A Working Place – the proposals are underpinned by an economic strategy to help transform the profile of the local economies, by attracting a more highly skilled demographic looking to locate here as a lifestyle choice, supported by employment floorspace provision.
7.5. This vision reflects the new requirement introduced through the Framework for larger scale developments ‘policies should be set within a vision that looks further ahead (at least 30 years),
to take into account the likely timescale for delivery’. The draft policy demonstrates the level of growth that is anticipated during this Local Plan (up to 2040) and also considers the longterm potential of this growth option up to 2050 and beyond. The emerging Masterplan has been
designed as such to allow for the delivery of individual villages which can all be connected in time but equally allowing for the villages to be independent in their own right with sufficient services and infrastructure to meet their needs without reliance on future growth to deliver infrastructure.
DRAFT POLICY: LAND SOUTH EAST OF ROCHFORD & NORTH OF SOUTHEND STRATEGIC
ALLOCATION
Land south east of Rochford, east of London Southend Airport and north of Eastern Avenue is allocated as a cross-boundary strategic growth location with potential to deliver around 10,000 homes on land in both Rochford District and Southend-on-Sea. Mixed-use development is
envisaged to deliver a minimum of 4,600 homes in Rochford District together with necessary community, employment, transport, green and blue infrastructure; of which approximately 1,850 dwellings are expected to be delivered in the plan period to 2040.
Development should include:
ƒ Housing - a minimum of 4,600 homes in Rochford District to including market and affordable housing, specialist housing for older persons, and self- and custom-build homes;
ƒ Employment – around 11 ha of employment land to include provision for flexible commercial floorspace or workspace hubs (Class E) within neighbourhood centres and industrial land located east of London Southend Airport; together with infrastructure to support home working;
ƒ Social and community infrastructure – including provision for local shops and services, multi-use community space, health and education infrastructure to be structured around 15 minute neighbourhood principles;
ƒ Enhanced transport infrastructure – including high quality bus services to key employment locations, town centres and rail stations, high quality infrastructure for walking and cycling and strategic highways infrastructure to enhance east-west connectivity and mitigate impacts.
Development should include a buffer to prevent coalescence with and maintain the separate identities of the settlements of Great Wakering, Little Wakering and Barling.
To guide development a Framework Masterplan SPD should be developed jointly with the Councils, local community, site promoters and infrastructure providers to ensure the comprehensive integrated development of land in both Rochford and Southend and to coordinate the delivery of infrastructure. This Masterplan should include:
ƒ A Green and Blue Infrastructure Strategy providing a coordinated framework for provision of publicly-accessible formal and informal open space, play space and other sport and recreational facilities and provide new green corridors linking the Southend Urban Area to
the River Roach.
ƒ A Transport and Movement Strategy which should prioritise cycle and pedestrian movements and public transport through development of a comprehensive pedestrian and cycle network including green sustainable transport corridors providing links to major trip generators and London Southend Airport Rail Station and linking the two rail lines; and wider measures to promote sustainable travel. The Strategy should address the
phasing of development with highways improvements necessary to mitigate the impacts of development.
ƒ A site-wide Energy Strategy detailing how the range of land uses and associated infrastructure across the masterplan will combine to achieve a site-wide net-zero carbon target. The scale of development and variety of uses presents opportunities to coordinate energy generation, transference and consumption, together with carbon sequestration to achieve net-zero carbon.
ƒ Infrastructure Delivery Plan - to coordinate the funding and delivery of development and on- and off-site infrastructure and addressing long-term stewardship of community infrastructure
Planning applications for development should be accompanied by a Phasing Strategy addressing the phasing of development and infrastructure; and a Sustainability Strategy outlining measured to be taken to achieve a net zero carbon development, high quality
digital connectivity, biodiversity net gain and to future proof development to achieve long-term sustainability.
Figure 7.2: Concept Masterplan for Land South East of Rochford & North of Southend
[SEE ATTACHED DOCUMENT]

CONCEPT MASTERPLAN
7.6. The ambition is to deliver a sequence of new ’15 minute walkable neighbourhoods’ with local services and a strong character and identity set within a high quality green network which connects Southend’s existing urban area and the new areas of growth through to the River Roach, whilst protecting important Estuary and wetland environments, historic environments and biodiversity. We want to deliver a vibrant place to live, work and visit which successfully integrates and improves coastal, rural and urban environments, delivers family housing in strong local communities and helps to deliver transformational change and growth in the local economy and new strategic infrastructure.
7.7. This approach embraces environmental, climatic, technological, social and economic resilience, aiming to futureproof the development and provide flexibility to accommodate design changes resulting from new ways of living, working and playing.
7.8. Considering the scale of the site and potential growth that can be accommodated in this location, it is anticipated that the scheme will be built out over many years. In order to provide a high-quality built environment that caters for the needs of people both now and in the future, it is necessary to develop a set of key framework principles that will underpin every masterplan
developed for the site.
7.9. Incorporated within this approach are a number of key factors that are certainties given current national policy objectives and personal lifestyle choices. Other factors are less clear, and a flexible approach will therefore have to be adopted to ensure the masterplan is capable of adapting to changing technology and trends as it is developed.
7.10. The certainties the masterplan will have to accommodate include;
ƒ Being digitally connected with high-speed internet access
ƒ Being ready for the net-zero carbon economy
ƒ Being socially connected
ƒ Being mobile

PHASING
7.11. The following section of these representations detail the key phases to the proposed growth option on land southeast of Rochford and north of Southend. It should be noted that these options are indicative only at this stage and we welcome the opportunity to develop these proposals in further detail with the Council, key stakeholders and the local community.
Figure 7.3 – Potential Phasing Sequence for Land at South East of Rochford and North of Southend [SEE ATTACHED DOCUMENT]
Early phase : 1-5 years. (Phase 2b)
ƒ East of Southend Airport: 1050-1100 dwellings, a primary school, a local centre including health uses and 10.35Ha of flexible employment land.
Middle phase : 6-15 years. (Phase 3b)
ƒ North west of Garon Park: 710-770 dwellings, a local centre including a small employment hub and health uses.
Late phase : 16-30 years (Phase 6a, 6b & 8)
ƒ (6a and 6b) Southwest of Little Wakering: 2,000 – 2,100, a primary school and a local centre including a small employment hub and health uses.
ƒ (8) West of Little Wakering: 850– 900 dwellings, a primary school and a local centre including a small employment hub and health uses.
KEY DESIGN ATTRIBUTES - EARLY PHASE : 1-5 YEARS. (PHASE 2B)
East of Southend Airport: 1050-1100 dwellings, a primary school, a local centre including health uses and 10Ha of flexible employment land.
ƒ To provide a new east-west transport link in the location of Warners Bridge next to the Airport.
ƒ To provide a new junction to allow Temple Farm and Purdeys Indus¬trial Estate vehicles to pass
through the area without impacting residential areas
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route eastwards
ƒ To provide easy walking and cycling access to support the vitality of Rochford Town Centre
(1.2miles convivial walk)
ƒ To provide a mixed-use village core with school, shops, health care and village square
ƒ To provide flexible expansion space for Temple Farm employment area and in close proximity to the new east-west transport link and railway bridge.
ƒ To provide the first phase of a wider community park that will in¬crease biodiversity along Prittle Brook to Sutton Road
Figure 7.4 – Early Phases of Strategic Growth with Rochford District Council
[SEE ATTACHED DOCUMENT]

KEY DESIGN ATTRIBUTES - MIDDLE PHASE : 6-15 YEARS. (PHASE 3B)
North west of Garon Park: 710-770 dwellings, a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route eastwards
ƒ To respond to the existing planning proposals for the Fossetts Farm area including the masterplan for Southend Football Stadium, the Homes England residential area of Prittlewell Camp and the Fossetts Way East residential area.
ƒ To provide highway connections from the east-west transport link to Fossetts Way and Eastern Avenue (A1159) allowing stadium traffic additional access opportunities.
ƒ To provide early access from Fossetts Way B&Q roundabout across Garons Park established access. This would allow the east-west transport link to be delivered as early infrastructure whist the opera¬tional needs of Garon Park and Golf Course continue without interruption through the development process.
ƒ To provide bus connection to Shopland Road, Stonebridge and The Wakerings.
ƒ To provide the second phase of a wider community park that will increase biodiversity along the brook to Shopland Road
Figure 7.5 – Middle Phase of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]
KEY DESIGN ATTRIBUTES - LATER PHASE : 16-30 YEARS (PHASE 6A & 6B)
(6a and 6b) Southwest of Little Wakering: 2,000 – 2,100, a primary school and a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route westwards and southwards.
ƒ To reserve land for a future phase secondary / academy school (a separate 9.45Ha parcel of land).
ƒ Integrate the farms and small holdings of: Barrow Hall Farm, Abbotts Hall Farm, Oldbury Farm, Morley Nurseries.
ƒ Integrated the setting of Stonebridge village.
ƒ To provide the third phase of a wider community park that will in¬crease biodiversity along the brook to Shopland Road.
ƒ To allow for not less than 450m off-set distance to properties of Little Wakering.
ƒ To retain the existing water reservoir for agricultural use Figure 7.6 – Later Phases of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]

KEY DESIGN ATTRIBUTES - LATER PHASE : 16-30 YEARS (PHASE 8)
West of Little Wakering: 850– 900 dwellings, a primary school and a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route westwards and southwards.
ƒ To integrate a reconfigured golf course that will sit within Rochford and Southend.
ƒ Integrate the farms and small holdings of Beauchamps.
ƒ Integrated the water bodies serving surrounding farmland.
ƒ To provide additional bus corridor south to allow access to Garons Park sports and leisure uses.
ƒ To provide extensive landscaped community parkland.
ƒ To ensure the setting of the village is not visually intrusive on the landscape
Figure 7.7 – Later Phases of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]

08. RESPONSE TO QUESTIONS RAISED IN THE CONSULTATION.

Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help
guide decision-making? [Please state reasoning]
8.1. Yes, we agree that a range of separate visions for each of the settlements is a helpful guide to decision making. In any event a separate vision will be required for the growth areas as required in the recently updated Framework which stipulates that for larger scale developments ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. A draft vision for South East of Rochford and North of Southend is
detailed at Section 7 of these representations.

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing
from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
8.2. We support and endorse the five main strategic priorities set out in the Consultation, which are follows:
ƒ Meeting the need for homes and jobs in the area
ƒ Making suitable and sufficient provision for retail, leisure and other commercial development
ƒ Making suitable and sufficient provision of infrastructure for transport, telecommunications,
waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
ƒ Making suitable and sufficient provision of health, security, community and cultural infrastructure and other local facilities
ƒ Making suitable and sufficient provision for climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape
8.3. These form the foundation for the Local Plan in which all growth options should be tested against to ensure that future development will deliver the strategic priorities and objectives of RDC.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please
state reasoning]
8.4. These representations wholly endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend which lies within our client’s land interests.
8.5. It is submitted that in order to deliver the ambitions of the Local Plan large scale growth focused in one location as per Option 3b is required. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic Growth Locations Study (2020).
8.6. Option 3b is the only option which will:
ƒ Provide the “critical mass” needed to secure transformational new infrastructure to mitigate the impact of future development and critically to address the chronic congestion currently experienced within the District
ƒ improve affordability
ƒ address the decline in home ownership
ƒ support a sustainable shift towards higher wage/skilled jobs.
8.7. It is not purported however that this strategy will meet Rochford’s full housing need over the lifetime of the Plan, thus Strategy Option 4: Balanced Combination is the preferred approach. The Consultation states that Option 4 could make best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2).We support Option 4 which will provided a varied supply of sites to make the local housing market as diverse as possible delivering a range of choice and competition to the market, thus offering the greatest chance that housing will be consistently delivery over the whole plan period. Crucially the Plan needs to incorporate large scale strategic growth as a Local Plan strategy that relies solely on smaller sites, or sites spread more evenly through the District will not have the potential to fund
new infrastructure and provide betterment to the current challenges facing the District.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and
renewable sources? Are there other opportunities in the District to supply lowcarbon or renewable energy?
8.8. Bellway have committed that all new homes will be ‘zero carbon ready’ by 2025 and net zero by 2050 as part of the Future Homes Task Force road map published in July 2021 entitled The Future Homes Delivery Plan. The headline goals include:
ƒ homes that are zero carbon ready and sustainable by 2025
ƒ production and construction methods that are net zero and sustainable by 2050, with substantial progress by 2025 and 2030;
ƒ businesses operations that are net zero by 2050 with a 50% reduction by 2030.
8.9. The roadmap sets a series of goals and milestones that need to be met along the way, incorporating government policies such as the Future Homes Standard and Biodiversity Net Gain.
8.10. The proposals on the subject site afford the opportunity to provide an exemplar new community
which sets the benchmark for development in the region and for future generations in terms of the low carbon / renewable energy. Our client is keen to explore the potential to set up a Rochford Energy Supply Company and how this could be achieved.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies?
Should the same principles apply everywhere in the District, or should different principles apply to different
areas? [Please state reasoning]
8.11. Yes, a charter should be included to ensure relevant place-making principles are applied to
different areas. The land in the Roach peninsula is precious, unique and has great potential for combining new neighbourhoods within an important landscape setting. It is a land asset that will require careful decision making and one that will enhance the legacy opportunities for the Council.
8.12. Our intention is to develop a long-term vision and planning strategy for the site, rather than to identify immediate development opportunities. We therefore have the opportunity to lay down the foundations for future plans. A charter can help this. With such a long term project, it can allow for changing stakeholders over many years to ensure greater consistency to long term goals.
8.13. Our approach will necessarily be ambitious, complex and multi-faceted. It will be a collective
endeavour from many and over many years. The charter can inspire each and every one involved. It can serve as a benchmark and help guide decision-making, particularly at those moments when what appears urgent in the short term, threatens to overshadow what its truly important in the long term.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new
Local Plan? Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning]
8.14. We support the preparation of design codes. Design codes provide briefing for consistency, from
site wide to detailed design. As such, each phase will require its own design code and each time a phase is complete, a review of the completed phase will inform the production of the design code for the following phase.
8.15. Typical content of a design code shall include -
ƒ Movement strategy where appropriate
ƒ Access and street hierarchy where appropriate
ƒ Landscape and open space strategy
ƒ Land use and mix
ƒ Density
ƒ Heights
ƒ Number of homes
ƒ Identity and character of buildings and public spaces
ƒ Employment

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
employment facilities or improvements to existing employment facilities?
8.16. Development of Land at east of Rochford and North of Southend and Rochford provides major
opportunity to:
ƒ Support workforce growth in the area
ƒ Attracting new employers –who will come because there is a large labour force in the catchment area, and it has some capacity within it.
8.17. In the absence of such growth, there are structural challenges which will loom large: with a growing elderly population which creates costs for the public sector –including in health, social care, pensions etc –but a declining number of people and businesses which are contributing to this through taxation. With an ageing population, housing growth is going to be important to
supporting the local economy and ensuring that local businesses can find staff over the mediumand longer-term.
8.18. The scale of growth envisaged at Option 3b is a potential major economic driver in its own right. As with other development schemes, it will support growth in the population which supports employment in consumer-related sectors (as well as supporting the construction sector over a sustained period).
8.19. In addition, it also provides the opportunity to transform the area’s wider investment appeal by
improving the skills profile through diversifying the housing offer and delivering family housing with space to work in an attractive residential environment with access to the coast, countryside and local facilities together with local work hubs which offer facilities. A lifestyle offer which attracts higher skilled residents can over time improve Southend and Rochford’s skills profile and
investment offer to businesses.
8.20. In an environment in which we are seeing shifts in how people work –and will no doubt see shifts in the sectoral structure of the economy –the potential for a high quality lifestyle, at a location which is well connected (to London and other parts of Europe) is one of the important ways in which Rochford can stand out.
8.21. Self-employment is significant and has been growing in the district. There is potential for further
growth in this area, and a need for infrastructure to support this. With changes in how we work, some of those who currently commute out to higher paid jobs elsewhere may spend more time working at home or locally. The digital infrastructure (and potentially some local workspace) is needed to support this.
8.22. There will still be jobs in schools, education, local shops and services. Development on land at Southend and Rochford will support jobs in these areas. There will also still be jobs in offices, on industrial sites and at Southend Airport.
8.23. Mixed-use development is envisaged in all neighbourhoods, which includes provision of flexible
commercial space in neighbourhood centres as well as delivery of the technology infrastructure to support home-working and home-based businesses.
8.24. In addition to this, provision of over 10 ha of employment land is envisaged in on the western side
of the site, providing opportunities for both growth of SMEs and for grow-on space for existing
businesses in Southend and Rochford.
8.25. Equally, this large area of employment land could provide the right location for a Southend University Hospital Relocation subject to wide ranging consultation. This new location could serve Rochford and Southend as it is halfway between the two town centres. A&E Blue light routes would also be more rapid as they could rely on the new sustainable transport corridor and avoid congestion.

GREEN AND BLUE INFRASTRUCTURE
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
8.26. As detailed in these representations, the ambition is to deliver a sequence of new ’15 minute walkable neighbourhoods’ with local services and a strong character and identity set within a high quality green network which connects Southend’s existing urban area and the new areas of growth through to the River Roach, whilst protecting important Estuary and wetland
environments, historic environments and biodiversity. We want to deliver a vibrant place to live, work and visit which successfully integrates and improves coastal, rural and urban environments, delivers family housing in strong local communities and helps to deliver transformational change and growth in the local economy and new strategic infrastructure.
8.27. It is considered that that new strategic green and blue infrastructure is essential in order to create the community envisaged in this location. We support the delivery of the South Essex Estuary Park and The Island Wetlands. In order to ensure these landmark green and blue infrastructure projects can be delivered this will need to be balanced with the Council meeting their strategic needs. The provision of growth in southeast of Rochford and north of Southend will enable investment into strategic green and blue infrastructure projects in the location. We welcome the opportunity to work with the Council in terms of the extent and location of the green
and blue infrastructure.
OPEN SPACES AND RECREATION
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver
improvements to open space or sport facility accessibility or provision?
8.28. A critical aspect in delivering a new community such as that proposed at Option 3b will be the
delivery of high quality public open space. The initial design work has considered green fingers separating the series of neighbourhoods as illustrated at Figure 5.2. Our client is keen to work with the Council to explore how the proposed scheme can contribute towards and assist in the delivery of the South Essex Estuary Park. Moreover, the proposed is of such a scale and critical mass that
will ensure each neighbourhood provides generous public open space and sports facilities.

HERITAGE
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best
address heritage issues through the plan? [Please state reasoning]
8.29. Rochford is identified as one of the top five local authorities in England as having heritage potential as defined by the Heritage Index 2020. This means that the District has untapped heritage potential and suggests that local heritage is a further asset for consideration to achieve the goal to grow the tourism economy. There is an opportunity through delivering growth in the district to celebrate the heritage assets of Rochford.
8.30. The Thames Estuary 2050 Growth Commission aims to utilise opportunities in existing sectors,
environmental assets and planned development to create a ‘tapestry of productive places’ along a global river. These assets present an opportunity to support the attractiveness of Rochford as a place to live, work and visit, and contribute to the potential for growth of the tourism economy in the District.
TRANSPORT AND CONNECTIVITY
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take?
[walking, cycling, rail, bus, road etc.]

8.31. We are on the brink of a transport revolution as a result of both technological advances and changes to social behaviour. For example, new technologies such as autonomous vehicles can help improve traffic flow or reduce the need for car ownership and changes in working habits may allow more people to work from home or closer to home. Both of these, when added to numerous other changes, will reduce the need and size for large highways infrastructure projects which will
cost large sums of money and have ecological impacts and may be over designed for behaviours in 20-30 years.
8.32. The scale of Option 3b is such that development in this area will deliver significant enhancements to public transport which will not only serve future residents but crucially provide local services to the existing community.
8.33. We need to ensure that high-quality public transport options are available for those that need
it, for example, high-quality dedicated bus services linking major growth locations in the Plan to local train stations ensuring that a realistic low carbon option for travel. The availability of highquality options for travel by sustainable modes must be key to encouraging people to leave their cars behind.
8.34 A Transport and Movement Strategy will be prepared for the proposals which will prioritise cycle and pedestrian movements and public transport through development of a comprehensive pedestrian and cycle network including green sustainable transport corridors providing links to major trip generators and London Southend Airport Rail Station and linking the two rail lines; and wider measures to promote sustainable travel. The Strategy will address the phasing of development with highways improvements necessary to mitigate the impacts of development.

Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the promoted
sites should be made available for any of the following uses? How could that improve the completeness of
Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
8.35. As detailed in the submitted proposals it is envisaged that this area south east of Rochford and north of Southend could be developed for a new growth location which will deliver a range of services and community infrastructure to serve the future residents and also due to the close proximity to the existing settlements of Stonebridge and Sutton will serve the existing community. The Masterplan has been designed to ensure that the existing settlements retain their own identity as proposed in the Draft Vision, however residents of these places should have greater access to services close at hand, including by sustainable means.

09. ECONOMIC BENEFITS TO ROCHFORD
OF OPTION 3B

This infographic provides an overview of the economic benefits that could be delivered through the development of a minimum of 4,600 dwellings together with approximately 11ha of employment space, as well as education, community and healthcare uses within Rochford District. The proposed expansion is expected to deliver a range of economic benefits during both the construction and operational phases which will make a positive contribution to the local economy.
[see document for full infographic]
the construction phase benefits:
Injection of private sector investment
Supporting direct construction jobs
Supporting indirect jobs in the supply chain
Contribution to Economic Output (GVA)

the occupational benefits
First Occupation Expenditure up to £25.4m
Resident Expenditure c.£131.7m
Direct operational employment 5,900
Direct operational employment 6,700
Indirect operational employment 1,700

the fiscal benefits
Business Rates £4.2m
Council Tax £9.6m
New Homes Bonus £26.5m

Please find attached the Spatial Options Consultation response from Rayleigh Town Museum.

We have particularly concentrated on the Heritage Topic Paper upon which we are very concerned about especially in relation to the proposed development within the Rayleigh Town Centre Conservation Area. The enhancement and protection of the many heritage assets within Rayleigh have been considered and we believe should be subject to protection.

I would also ask that a receipt of this email is forwarded to me to ensure our views are considered.



Comments and Observations regarding the Heritage Topic Paper
Following the opportunity to consider the above the Trustees of the Rayleigh Town Museum would like to make a number of comments and observations in regard to the outlined spatial Options Consultation Paper whilst you are preparing for the new Local Plan.
There are a number of issues that give concern especially with regard to the Proposed sites as outlined within the interactive map layers.
It can be seen that the areas identified are:
• The Mill Hall site incorporating the Bellingham Lane car park, Windmill and the Mount area;
• The site of the former Dairy at the rear of the High Street;
• The site of Barringtons and the present Council Offices and car park on Websters way and Hockley Road;
• The land adjacent to the Post office Sorting Office and houses 168, 166, 162 and 164 as well as 156 to 155 High Road;
• In addition there is the issue of the present Building Plot under construction where Luxury Penthouse Flats are being completed overlooking the Marks and Spencer Car Park;

Our Major concern appears to be the total disregard to the fact that outlined within the spatial consultation all these proposed sites lie within the Conservation area of the Rayleigh Town Centre.
The National Planning Policy Framework outlines the following:
‘Strategic policies should set out an overall strategy for the pattern, scale and quality of
development, and make sufficient provision for (inter alia) the conservation and
enhancement of the natural, built and historic environment, including landscapes and
green infrastructure, and planning measures to address climate change mitigation and
adaptation (Paragraph 20)’

Paragraph 20 is self-explanatory when it comes to strategic policies and the need to ensure that sufficient provision for the conservation and enhancement of the natural, built and historic environment. The centre of Rayleigh Town is primarily a natural, built and historic environment which needs sympathy and protection from redevelopment not in keeping with its present historic nature.

There are a number of individual historic landmarks within the conservation area including:

• The site of the Rayleigh Mott and Bailey Castle a recognised designated historical asset located on the Mount on Bellingham Lane which was gifted to the National Trust by Edward Francis. The Mount is also identified as a scheduled Ancient Monument;
• The Rayleigh Windmill Grade II listed built in 18th Century again within the Bellingham Lane complex;
• Grade II Listed Holy Trinity Church at the top of the High Street on the junction of Hockley Road, London Hill and the High Street built c1380 although there the same site has been one of religious observance for 1000 years;
• Barringtons House Grade II listed House built in Mid C 19 on the junction of Websters Way and Hockley Road;
• Martyrs Memorial built in 1908. It commemorates four local Protestant martyrs, who died in 1555 during Queen Mary's reign.
• Dutch Cottage which is presently outside the Conservation area but is still a recognised historic landmark which was thought to be built in the 18th Century.
• 91 High Street a Grade II listed building the oldest secular building which presently houses the Rayleigh Town Museum;

It is the opinion of the Trustees of Rayleigh Town Museum that the Heritage Assets within the Conservation Area may suffer extreme harm and certainly will not be enhanced as required by the National Planning Policy Framework.

Paragraph 4.5 outlines the differing heritage assets and it can be seen from the list above we have outlined are present within Rayleigh certainly within the categories of:

• Listed Buildings;
• Scheduled Monuments;
• Conservation Area.

There are a number of observations that we require some explanation for including:-

On page 6 it identifies that Local Authorities from time to time review their conservations areas- we would be extremely interested in when the last conservation area was reviewed?

On Page 8 - 4.6 and 4.7 it outlines – Does the council have an Updated Local List that would identify the heritage assets that are Designated and Non-designated.

On Page 9 – 5.4 it makes mention of the Essex Historic Environment Record and we would be interested in more of an explanation as to the purpose and when did the EHER last carry out a survey of the significant areas which are of archaeological interest or potential archaeological interest.

General Observations

Areas of General Observation within the Heritage Topic Paper.

We note that there are a number of areas that the Rayleigh Town Museum could assist with during the process of the Spatial Options Consultation. We would be keen to act as a consultee in respect of the following areas:-

• Any conservation area appraisal;
• Any procedure that Rochford undertake in respect of Heritage and the effect of planning upon those Heritage Designated and Non-Designated Assets.

In Conclusion

The Significant heritage of the Rochford District must be a key element in any/all future planning considerations and related infrastructure developments to help ensure its long term protection. Rayleigh Town Museum is most keen to work and assist in that protection.

Persimmon Homes is a FTSE 100 housebuilder with a national presence. In 2020 the Group delivered 13,575 new homes, down from 15,855 in 2019 (largely in part due to the impact from Covid-19 on operations), although the selling price increased by about seven per cent.
Persimmon Homes has a strong presence in Rochford, having an option to deliver site CFS087: Land between Western Road and Weir Farm Road Rayleigh, and are actively seeking additional sites in Rochford to deliver much needed housing and regeneration in the Borough. Persimmon Homes welcomes the opportunity to comment on the New Local Plan Spatial Options Consultation Paper 2021.

In the short term, Persimmon Homes is aware that Rochford’s existing Local Plan is now out of date, as per the tests of the NPPF. Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF. The Rochford District Core Strategy, which was adopted in December 2011, fails to meet the requirements of the NPPF. Therefore, it is imperative that the draft Local Plan continue to be progressed to allow it to be adopted as soon as possible so that the District can continue to plan effectively to meet the District’s ongoing needs.

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?

The technical evidence that Rochford is preparing is comprehensive, though we would suggest the following additional evidence (which may be included within the evidence base documents listed) will also be required to inform the new Local Plan:

Heritage

An ‘initial Heritage Assessment’ is listed, which is vague, which is not sufficiently detailed or robust to properly consider the relationship of heritage assets and emerging site allocations. Persimmon Homes is, in particular, concerned that it identifies site CFS087 as having a ‘moderate-adverse’ impact on the Grade II listed Weir Farmhouse, despite this asset being located some distance from site CFS087 and screened from view (as would have been evidence if Place Services had undertaken site visits) by existing mature vegetation and twentieth century housing developments. The heritage asset listed within Place Services report therefore has no relationship with our allocated site, and cannot be seen from the site.

It is recommended therefore that the Council’s Heritage Evidence Base will need to be properly updated to include, at a minimum, some or all of the following:

• A Heritage Asset Review, to assess the significance of heritage assets and the contribution they make to their environment;
• Lists of Buildings of Local Architectural or Historic Interest;
• Conservation Area Character Appraisals Programme – noting that these were last reviewed in 2008 and therefore these need updating so that the Council have up to date evidence and therefore able to properly consider applications affecting these assets;
• Historic Environment Characterisation Studies; and
• Heritage Impact Assessments, and Archaeological Evaluation Reports, where relevant, on each allocated site. We would strongly recommend that these are prepared in accordance with each site developer and will need to involve site visits, rather than relying on a simple mapping exercise.

Highways

An ‘initial Transport Assessment’ is listed as being provided, which is a vague description and does not specify the required level of detail to support the Plan. It is recommended that this will need to include, at a minimum, some or all of the following:

• Transport evidence for the new Local Plan;
• Transport evidence mitigation;
• Sustainable Modes of Travel Strategy;
• Cycling Action Plan/Local Walking and Cycling Infrastructure Plan/Cycling Delivery Plan;
• Transport modelling of key strategic routes/junctions – the Spatial Options Document goes on to highlight the congestion affecting the road network, and identifies the improvements already planned for the A127 and Fairglen Interchange; and
• Infrastructure Delivery Plan.

Housing

Alongside the HELAA and SHMA, we would recommend the following:

• Self-Build Custom Build Housebuilding Register;
• Housing Implementation Strategy;
• Settlement Capacity Studies;
• Brownfield Land Registers;
• Schedule of Brownfield Sites and Extant Permissions; and
• Housing Trajectories.

Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included?

The draft vision at present appears to be too vague and lacks a real vision. It is clear that the two big challenges facing the country in the next 20-30 years are a lack of homes, particularly for both young and elderly, along with the impending threat of climate change and its attendant impacts. Therefore, both of these need to be reflected in the vision. Rochford should strive, in its local plan, to not only meet its housing supply but to plan beyond, as well as to meet the threat of climate change by encouraging
all developments to be ‘green’, to exceed climate change targets and to seek alternatives to the private car to transform how Rochford residents travel.
For example, the ‘Our Society’ vision needs to have a greater vision for the delivery of new housing and
supporting infrastructure. Rochford should welcome the challenge of building at least 360 homes per year, by choosing to focus on high quality developments and the attendant benefits of planning for the delivery of these homes.
Similarly, the ‘Our Environment’ vision does not refer to climate change, which is a missed opportunity, given the pressing need facing the Country in addressing Climate Change impacts and its repeated messages within the NPPF, particularly as detailed within Chapter 14, and at paragraph 153 which states that, “Plans should take a proactive approach to mitigating and adapting to climate change…”.
Alongside this, the Covid-19 pandemic has transformed how people work, with more people now choosing to work from home, more often. This needs to be reflected in the ‘Our Economy’ vision – can Rochford provide the employment hubs and flexible working conditions to meet the new ‘normal’ for example.

Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?

Persimmon Homes would agree that separate visions for each settlement would help guide decision making and notes, for example, the wide character as detailed within the settlement profiles from page 71 onwards of the Spatial Options paper. This confirms that Rochford ranges from Tier 1 Settlements such as Rayleigh with 34,000 residents, to isolated hamlets such as Paglesham and Stonebridge of only 250 residents. Clearly, the type and level of development is going to differ and a set of visions for each settlement would provide clarity to developers on the type, and level, of development that would be appropriate. Such vision statements could usefully be informed by the following:
 Historic Environment Characterisation Studies;
 Heritage Impact Assessments;
 Settlement Capacity Studies;
 Transport Studies and Strategies;
 Green Belt Studies;
 Strategic Land Availability Assessment;
 Flood Risk Assessments;
 Design and Development Briefs; and
 Masterplanning Studies

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

The Spatial Options Paper lists 23 Strategic Options and Persimmon Homes broadly agrees with these, though we would have the following observations to make:
 Strategic Objective 1 – Persimmon Homes understands the Council’s reasons for looking to prioritise previously developed land first. However, the Paper goes onto confirm at page 29 that previously developed land will not be able to meet the Council’s housing targets in full; therefore there is no justification in prioritising previously developed land first. In many cases, greenfield sites are able to be brought forward quicker than previously developed land, particularly in the case of previously developed land having existing uses that need to be relocated first, or contaminated land that requires remediation. Accordingly, this objective could be reworded as follows:
“To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through working with our neighbours in South Essex and encouraging the redevelopment of previously developed land alongside suitably located greenfield sites to ensure the plan requirements are met in full.”
 Strategic Objectives 4 and 5 – these objectives could usefully reference the change in remote working patterns and confirm that Rochford will promote the use of flexible working practices to meet the needs of the ‘new normal’ arising from Covid-19, as well as offering flexible work
spaces to meet the needs of the 21st Century Office;
 Strategic Objective 6 – we would disagree with the phrasing ‘highest attainable quality’ as this is vague and imprecise; design is, to a large degree, subjective (particularly moreso where Local Authorities lack design codes and guides to guide the design of built form). We would therefore recommend the following revised wording:
“To ensure that all new homes and commercial premises are built to a high quality design and sustainability standard with a good level of access to green space and the countryside.”
 Strategic Objective 13 – this objective could usefully highlight Governments’ requirement to direct development to Flood Zone 1 (i.e. areas at the lowest risk of flooding);
 Strategic Objective 23 – the sole objective relating to climate change could usefully reflect Governments’ Future Homes’ requirement (being introduced in 2025).

Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
Persimmon Homes would agree with the settlement hierarchy presented, which demonstrates that growth should be predominantly located at Rayleigh, Hockley and Rochford. As Rayleigh is the sole ‘Tier 1’ settlement, it is logical that as the Plan progresses, that Rayleigh takes a larger proportion of development than other settlements.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

The NPPF makes it clear at para 61 that Local Planning Authorities should be looking to use the Standard Method to determine how many homes are required, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…”.
Accordingly, it is confusing at Figure 15 that it includes a ‘current trajectory’ scenario of only 4,500 homes when this scenario will not deliver the Standard Method requirement of a minimum of 7,200 homes. The Council could, therefore, be clearer in this regard and confirm that this Scenario cannot be taken forward in isolation.
The Plan presents four options; Persimmon Homes would support a combination of Options 1 and 2.
Our comments of which are as follows:
 Strategic Option 1 – The Paper itself acknowledges that this Option will not be able to fully meet the Standard Method requirement, as well as acknowledging that it will not be able to deliver the brand new infrastructure that is required alongside new homes.
It is also identified within the Integrated Impact Assessment that the lower growth options will not deliver the required levels of growth, stating on page 25 that:
“The lower growth option will not meet the needs of all people in the district during the plan period. The medium and higher growth options will meet the needs of all people in the district and improve accessibility to housing, employment, training, health, and leisure opportunities.
The higher growth option is more likely to meet the needs of not only people in the district but beyond, as well and encourage the integration and interaction of cross-boundary communities through the delivery of large-scale developments. The medium and higher growth options are also considered for their overall potential to deliver a wider range of housing types, tenures and
sizes, particularly catering for the needs of groups with protected characteristics, such as specialist housing for the elderly and disabled.”
Furthermore, the Integrated Impact Assessment states that: “…smaller scale development proposals bring less opportunity for strategic infrastructure improvements, and may place increased pressure on local road networks.”
The Paper also identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
It also goes on to confirm
"Option 1 would not deliver sufficient housing to meet local needs over the Plan period, in this respect it is also likely to deliver less affordable housing and long-term negative effects can be anticipated.”
Again, we would request that the Council undertake updated Conservation Area Appraisals and Settlement Surveys so that the Council has the required evidence base to consider if increased densities, taller buildings etc. would be appropriate in the historic centres and urban areas, as this would help inform the actual number of dwellings available under this option.
We would also question that this Option uses sites that have retained site allocations from the 2011 Core Strategy, and would question why these sites have not been developed by now – are these sites developable and deliverable as per the tests of the NPPF. This is something that the District Council should review.
Accordingly, this option cannot be taken forward within the next stage of the Local Plan on its own, though it is acknowledged that some level of urban intensification on appropriate sites may be suitable to help meet the Standard Method.
 Strategic Option 2 – Option 2a proposes Urban Extensions focused in the main towns; as Rayleigh is the Districts sole Tier 1 settlement, it is logical and sensible that urban extensions should be focused in Rayleigh. Furthermore, it benefits from not being restricted by any flood zones, being sequentially preferable to many other settlements in the District.
The Spatial Options document identifies that this option would be able to deliver new infrastructure; meet local housing needs; and deliver quickly; all of which Persimmon Homes endorses.
This Option would also deliver the required level of growth required for employment needs, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is considered less likely to lead to positive effects of
significance.”
It goes on to state:
“Urban extensions under Options 2a and 2b provide large scale development opportunities that can deliver new infrastructure provisions to support both existing (particularly those in edge of settlement locations) and future residents.”

It concludes:
“Significant positive effects are considered likely under Options 2a, 2b and 4.”
The delivery of sites under the medium and higher levels of growth would also allow for the delivery of climate change measures that are required and discussed later in the Spatial Options Document. The delivery of these measures may not be possible through reusing
existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”
On the same theme, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as also confirmed within the Integrated Impact
Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland.
The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance &
Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population. As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential for greater net gains in biodiversity.”
The site that Persimmon Homes is promoting – site CFS087 – would be capable of being delivered under this Option.
 Strategic Option 3 – The Spatial Options document identifies a number of significant ‘Cons’ which would impact upon the delivery of this option (and thus threaten the delivery of the plan as a whole), all of which we would agree with and would therefore recommend that this option is not progresses as:
o The plan identifies that this option involves complex land ownership issues which is likely to be difficult to resolve and address;
o Significant redrawing of the Green Belt boundaries, including proposing development in more sensitive Green Belt locations than other strategic options;
o Focussing development in a single location/settlement would deprive other settlements of being able to accommodate development, and thus potential infrastructure improvements.
On Environmental impacts, the Integrated Impact Assessment identifies that harm that this option would have on Environmental Quality, stating that:
“…extensive countryside development proposed through the concentrated growth options (Options 3a, 3b and 3c); which is considered highly likely to lead to negative effects of significance in this respect. Options 3a and 3b are also likely to intersect the flood plains of the Crouch and Roach tributaries, and development will need to ensure appropriate mitigation to avoid impacts on water quality…Negative effects of significance are considered more likely under Options 3a, 3b, 3c and 4 given the extent of concentrated growth development locations
in the countryside.”
 Strategic Option 4 – This option proposes a ‘balanced combination’ of all three; we would recommend a balanced combination of Options 1 and 2 represents the most suitable Spatial Strategy going forwards for the reasons given above and indeed as detailed within the Spatial Options document, and the Integrated Impact Assessment, which concludes:
“Option 4 is noted for its potential to perform better against a wider range of the IIA themes than the remaining options. This predominantly relates to the flexibility provided in a tailored approach, essentially combining the best performing aspects of each individual approach (urban intensification, urban extensions and concentrated growth).”

Q7. Are there any reasonable alternatives to these options that should be considered instead?

Southend are currently consulting on its ‘Local Plan - Refining the Plan Options’, with the Consultation running through until 26 October 2021. The NPPF is clear that Local Authorities should also plan to meet housing needs that cannot be met within neighbouring authority areas (para.61), stating that, “In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”.
In this regard, it is noted that within their Plan proposes a ‘Development Opportunity D’ of c.10,000 homes, of which 4,900 homes lies within Rochford.
It is imperative, therefore, that Rochford works alongside Southend to understand if it needs to plan for these 4,900 new homes alongside its own minimum of 7,200 homes, which would need to be reflected within the next stage of the Rochford District Local Plan.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?

Persimmon Homes would request that further spatial themes topic papers are required, or updated, for:
 Place Making and Urban Design – further questions within the Spatial Options paper deal with design (Q14 – Q16), but as yet a corresponding topic paper has not been published to consider this issue. The NPPF places an increasingly strong emphasis on design, with the recent 2021 revision further emphasising the Governments’ commitment to building ‘beautiful’ homes and places, to be underpinned by Design Codes and guidance. Understanding how Rochford District Council intends to interpret this requirement will be key for Developers as the plan progresses and beyond.
 Flood Risk and Drainage – Briefly discussed within the Climate Change topic paper, but this issue needs to be sufficiently evidenced as the plan progresses.
 Landscape and Visual Impacts – As above.
 Heritage – The Heritage Topic Paper confirms that existing Conservation Area Appraisals date back to 2007 (if they exist at all) and that these, along with the ‘Local List’ may be updated as the Local Plan progresses. Persimmon Homes would strongly support this evidence being undertaken as understanding heritage impacts is often key, which cannot be understood without up to date evidence.
 Duty to Co-Operate and Strategy Options – As identified at Q7, these topic papers do not address the potential for Rochford needing to meet Southend’s housing needs, as is currently presented as a potential option within their new Local Plan ‘Refining the Plan Options’ consultation.

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

Persimmon Homes strongly recommends that Rochford take the sequential approach to Flood Risk as required by paragraphs 161-162, confirming that new development should be directed to areas with the
lowest risk of flooding from any source.
The flood map at Climate Change and Resilient Environments Topic Paper identifies that the four
settlements least impacted by Flood Zones are Rayleigh, Hullbridge, Hockley and Ashingdon, and therefore these settlements are sequentially preferable for residential development to meet the Local Plan needs than those settlements that lie within Flood Zones 2 or 3 (such as Great Wakering).
We would also take this opportunity to identify to the Council that the site that Persimmon Homes is
promoting (Site CFS087: Land between Western Road and Weir Farm Road, Rayleigh) lies within Flood Zone 1 and is therefore sequentially more preferable than those sites being promoted that lie within Flood Zones 2 and 3.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply lowcarbon or renewable energy?

Climate change is a principal risk for Persimmon Homes and a significant issue, with more extreme weather events such as heatwaves, rising sea levels and flooding being experienced and resulting in impacts of both global and local significance. Society is more environmentally conscious with the international community and Government taking a leading role to reduce greenhouse gas emissions by setting and legislating ambitious targets for all to achieve.
As one of the UK’s leading house builders we acknowledge our role in supporting these common aims.
We understand the risks and challenges that climate change presents to our business and the wider industry. We are proactively working with all stakeholders to more effectively integrate climate change issues within our operations and ensure that sustainable improvements are managed in a pragmatic and robust manner.
We recognise that we have a key role to play in minimising our contribution to climate change, through
our own operations, our supply chain and by striving to ensure that the homes and communities we build are sustainable, inherently energy efficient and encourage our customers to live in a way that minimises any impact to climate change. We are committed to working alongside all stakeholders to achieve this.
Working with the Carbon Trust, a global climate change and sustainability consultancy providing specialist support to assist businesses to reduce their greenhouse gas emissions, Persimmon has set ambitious targets to be net zero carbon in our homes in use by 2030 and in our operations by 2040.These targets are supported by interim science based carbon reduction targets to reduce greenhouse gas emissions from our own operations by 46.2% (2019 baseline) and our indirect operations (i.e. those from our homes in use and our supply chain) by at least 22% per m2 completed floor area by 2030 (2019 baseline).
Referring back to the Spatial Strategy Options, the delivery of sites under the medium and higher levels
(Strategy Options 2 & 3) of growth would allow for the delivery of climate change measures that are required. The delivery of these measures may not be possible through reusing existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

Persimmon Homes would support new homes being built to meet the new Future Homes Standard (being introduced from 2025), which proposes an ambitious uplift in the energy efficiency of new homes through changes to Part L (Conservation of fuel and power) of the Building Regulations. This will ensure that new homes produce 75-80% less carbon emissions than homes delivered under current regulations.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies?
Should the same principles apply everywhere in the District, or should different principles apply to different areas?

As the Spatial Options document identifies, Rayleigh is diverse area with a mix of character and vernacular. Accordingly, a ‘Place-Making Charter’ would be welcomed as an overarching theme to guide all new development in the area during the plan period. Persimmon Homes welcomes the Government’s increasingly strong emphasis on design and place making, noting and agreeing with the Government’s statement at paragraph 126 of the NPPF that, “high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve.”
Accordingly, the more guidance on this that Rochford can produce (noting that design is often, subjective and without suitable guidance, decisions can be delayed), would only assist developers in understanding the Council’s aspirations in this regard. This would be supported by paragraph 126 of the NPPF, which states that, “being clear about design expectations, and how these will be tested, is essential for achieving this.”
It would also assist decision making in local residents and members are involving in the creation of
place-making charters and other design guidance; to ensure that design is properly considered by members and local residents at an early stage in the process and to ensure their views on design and place making are heard early; rather than such views being made during the application process (such as at Committee) which will delay decision making.
This would also identify if the same principles should apply throughout the District, or if certain settlements have specific principles and design, requirements that only apply to their settlement for example. Such an approach would be supported by paragraph 127 of the NPPF (“Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.”)
As above, the more guidance that can be produced, and the more involvement and agreement with local residents/members, can only guide and aid the decision making process.
Of the principles identified within Spatial Options paper, the majority of these would apply everywhere in the District, albeit on some sites certain principles may not apply (impacts on the historic environment for example).
On Design Codes, the NPPF confirms at paragraph 128 that, “all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.” Persimmon Homes would support Rochford District Council in the preparation of
Design Codes in the District.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?

Persimmon Homes would broadly support the draft Place-Making Principles, as they would provide a
broad framework for future Design guidance and policy produced by the Local Authority. We note however that there is not a principle relating to Biodiversity; given the Government’s commitment to ensure that development pursue opportunity for net gains to Biodiversity, it may be appropriate to reflect this within the place-making charter.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?

Persimmon would welcome the use of design guides, codes or masterplans, which would be supported by the NPPF:
“Being clear about design expectations, and how these will be tested, is essential…” (para. 126)
“Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable.” (para. 127)
“To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences.” (para.128)

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?

Persimmon Homes would refer to paragraph 129 of the NPPF:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop.
Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area, taking into account the guidance contained in the National Design Guide and the National Model Design Code. These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes.”
However, given the variety of settlements and styles within Rochford, we would suggest that separate
Design Codes be created for each settlement.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

The National Model Design Code, published July 2021, confirms that the preparation of a Local Design Code should follow seven steps:
1. Analysis.
1A - Scoping: Agreeing on the geographical area to be covered by the code and the policy areas that it will address.
1B – Baseline: Bringing together the analysis that will underpin the code and inform its contents.
2. Vision.
2A – Design Vision: Dividing the area covered by the code into a set of typical ‘area types’ and deciding on a vision for each of these area types.
2B – Coding Plan: Preparing a plan that maps out each of the area types and also identifies large development sites from allocations in the local plan.
2C – Masterplanning: On larger sites working with land owners and developers to agree a masterplan for each of the development sites establishing the key parameters and area types.
3. Code.
3A – Guidance for Area Types: Developing guidance for each area type by adjusting a set of design parameters.
3B – Code Wide Guidance: Agree on a set of policies that will apply equally across all area types.
We would advise the District Council to use the Model Design Guide as the basis for the production of
all Design Codes in the District.

Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?

Of the options listed, Persimmon Homes would support:
 Option 2 – requiring a suitable or negotiable mix of housing that is response to the type or location of development;
 Option 5 – all homes to meet NDSS;
 Option 6 – all homes to meet M4(2); and
 Option 7 – a proportion of homes to meet M4 (3).
Option 1 listed proposes a non-negotiable mix to be provided on all housing developments. Clearly, this
option is unworkable in practice as certain sites are unable to deliver certain types of housing. For example, Brownfield sites in the urban areas are unlikely to be able to deliver suitable proportions of larger dwellings; likewise, heritage constraints in certain areas may influence the size of dwellings that a site could deliver to satisfy historic environment consultees. It is therefore more appropriate to require housing mix to be agreed during pre-application discussions, having regard to site and location characteristics, with the latest SHMA evidence used as a broad guide to inform those pre-application discussions.

Similarly, option 3, which proposes to allocation specific sites for certain types of housing, such as affordable homes, would have the potential to result in ‘ghettos’ and not created mixed inclusive communities (as required by paragraph 92 and 130 of the NPPF; good place-making would be achieved by requiring all developments to deliver policy compliant levels of affordable or specialist housing (subject to viability etc.) and to ensure that housing is of the same build quality/appearance as the
market housing.

Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?

Guidance confirms that net gains should normally be delivered on site. However, where achieving biodiversity net gain is not possible on site whilst still delivering a viable project; developers have the option to contribute at a local or regional scale to off-site Offsetting or Compensation. This approach can often successfully result in greater gains for biodiversity than could be provided within a constrained development site. It supports delivery of Local Nature Recovery Strategies and is consistent with the central conclusion of the 2010 report ‘Making space for nature’, that we need more, bigger, better and joined up habitats.
Referring back to the Spatial Strategy Options, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland. The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population.
As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential
for greater net gains in biodiversity.”

Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?

Persimmon Homes would support a combination of option 1 and 3 listed on page 55 of the Spatial Options document to address green and blue infrastructure through the Local Plan:
 Option 1 – Allocating specific areas of land for strategic infrastructure appears a sensible and logical strategic objective to deliver tangible green and blue infrastructure through the course of the Local Plan. Strategic policies to the enhancement and protection of these areas would
be required to provide a policy framework for these specific areas (the coastal path project and South Essex Estuary Park for example), and contributions towards funding these projects could be secured, where required/relevant etc., through S106 contributions or CIL;
 Option 3 – Development sites of a certain scale (particularly edge of settlement, greenfield sites) are typically capable of being able to deliver on-site green and blue infrastructure; of providing connections to green and blue infrastructure through their site; or of securing financial contributions to improving green and blue infrastructure in the local area. With reference to our
site at Western Road, Rayleigh, the site benefits from an existing public right of way running through the centre of the site, and informal footpaths running along the southern boundary along the woodland edge. These informal paths have to be managed yearly in order to maintain these paths for the use of existing residents; without this regular maintenance these footpaths
would not be usable. The development of the site therefore look to retain these links and provide permanent, sustainable connections and to enhance these where possible, providing improved footpaths and links to the surrounding area, including to Kingley Woods to the west of the site. Access to the wider countryside can also be promoted through the development as
existing footpaths can be improved and maintained. There is scope to enhance the Green Infrastructure Network in the locality by providing more formalised and accessible links through the green spaces.

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?

With reference to the four options, we would comment as follows:
 Option 1 – support the protection of existing school and healthcare facilities through specific allocations.
 Option two – support the allocation of specific sites for the creation of new community infrastructure (providing that site is being allocated for that use or would not conflict with other site promotions).
 Option 3 – Broadly support requiring new developments to deliver new community infrastructure on site, though would caution that this would only apply to sites of a certain scale.
For example, the Essex County Council Developers’ Guide to Infrastructure Contributions highlights that developments with an individual or cumulative size of 1,400 homes are likely to be required to deliver a new two-form entry primary school, whilst developments with an individual or cumulative size of 4,500 homes or more will need to provide a new two-form entry secondary school. It would be simpler for the LPA to identify new sites for community infrastructure (new schools/extensions to existing schools, new surgeries/extension to existing surgeries etc.), and require developments to contribute towards those new facilities (with reference to para.34 of the NPPF requiring that Local Plans should clarify the level of contributions expected from new developments).
With reference to the Spatial Strategy Options, the Integrated Impact Assessment states:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is
considered less likely to lead to positive effects of significance.
We would also question whether the Council intends to progress with a Community Infrastructure Levy, to fund the development of new infrastructure in Rochford, as no reference is currently found on the Council’s website (and no reference is made to CiL within the Spatial Options Document). CIL is seen by many as creating a more transparent contributions system, whereby developer contributions can be calculated upfront (which assists developers with viability calculations, as well providing clarity to local residents/interests groups on the level of funding provided by new development and where that funding is directed towards).
Persimmon Homes would support Rochford District Council in the development of a Community Infrastructure Levy.

Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?

Persimmon Homes would request that the Conservation Area Appraisals be updated as part of the emerging Local Plan process; these were last produced in 2007 so by the time the plan is adopted, these will be over 15 years old. The Local Authority are aware that settlements and areas change over time, and as such, it would assist greatly for these documents to be regularly reviewed.
Persimmon Homes are also concerned that our site at Western Road, Rayleigh (ref. CFS087) is marked poorly in the accompanying Site Appraisal Paper due to impacts on Built Heritage. This appears to have been assessed purely on the basis that there is a listed building – the Grade II listed Weir Farmhouse (List UID: 1322351) – but that this assessment has seemed to be have been undertaken purely as a mapping exercise and without any consideration to the sites relationship to this asset on the ground. The listed building is located a considerable distance from our site, and is screened from view not only by existing twentieth century development but also by considerable mature trees (which would be retained as part of any development proposals); therefore development of our site (ref. CFS087) would have no impacts on the setting of this listed building, as is fully confirmed within the Heritage Statement that accompanies these representations.
With reference to the Spatial Strategy Options, the Spatial Options Paper identifies that said option to
increase densities in urban areas are unlikely to be compatible with historic centres and local character,
as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
We would therefore recommend that all assessments of built heritage impacts be fully assessed by up to date evidence, noting that the Council’s Conservation Area Appraisals haven’t been updated since 2007 and therefore may not accurately reflect existing site conditions.

Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
Persimmon Homes would support the four options listed to address transport and connectivity through the plan.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]

With reference to, our site at Western Road, Rayleigh (ref. CFS087), and the site is within a very sustainable location being walking distance to local amenities including schools (0.6 miles) and a train station (1.1 miles). A main bus route also runs in very close proximity to the site. The wider main road network is also easily accessible.
The development will provide betterment to existing footpaths, creating enhanced foot and cycle links to services and employment areas for new and existing residents. The existing PROW could be upgraded into a cycle link and a formal path that can connect to an east/west foot/cycle link that runs from Western Road to Weir Farm Road. This will allow a good connection to High Road and therefore services/employment/further transport networks. As previously stated, existing footpaths running through the site are informal and could be upgraded as part of the redevelopment proposals for the site to provide permanent, sustainable connections for existing and new residents.
Access to the wider countryside can also be promoted through the development as existing footpaths can be improved and maintained.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
Persimmon Homes agrees with the vision for Rayleigh. As the District’s only Tier 1 settlement, it is correct that it should take large proportion of the District’s Plan Requirements during the Plan Period.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other

Persimmon Homes is promoting site CFS087 for residential development. This 10-acre site is located
north of the A127 by Rayleigh Weir. The site is contained between the current residential area defined by the southernmost extent of Western Road and Eastern Road with the A127.
The majority of the site comprises rough grassland, which has no beneficial use. There is a Public Right
of Way (No25) running south from Eastern Road. The development offers the opportunity to formalise footpath links from Western Road. It would also offer the opportunity to create recreational routes through to Weir Farm Road. The allocation has the potential to enhance the Green Infrastructure Network in the local area.
The site benefits from being closely related to the existing built up area of Rayleigh, its town centre, train station, bus routes and key services. The Vision is that the site will add to the growth of Rayleigh, providing homes in a sustainable location close to existing services, transport links and accessible green space.
The site is located immediately south of the Main Settlement of Rayleigh and north of the A127.
Rayleigh Town Centre is within a 10-minute walking distance and the Train Station, with a direct link into London, is only 1.1 miles walking distance. A main bus route linking the town centre/train station, Southend, Basildon and Canvey Island runs through High Road. This is in close proximity of the site. The site has good access to the wider main road network.
The site is within walking distance to the nearest Primary and Secondary School (0.6 miles and 1.1 miles respectively).
The development of the site would provide beneficial enhancements to the public open space provisions
and improved walking/cycling links across the site to encourage new and existing residents to use
sustainable modes of transport.
The site does not serve the five purposes of Green Belt (as confirmed within the Council’s evidence base) and would benefit from housing development to allow for improved biodiversity creation and management. Development of the site would also provide an enhanced settlement boundary to the A127 and provide an improved setting for Ancient Woodland and Local Wildlife Site.
Development of the site will allow for delivery of required housing in a sustainable location.
Persimmon Homes are currently preparing an updated Promotional Document to support the allocation of the site for residential development, which will be submitted shortly.

Conclusion
The adoption of the new Local Plan (2023) remains, optimistically, 2 years away. The Council does not
have a published strategy for bolstering housing land supply in the period up to the adoption of the new Local Plan. The Council need to identify a strategy to boost significantly the supply of housing in the period up to the adoption of the development plan, such measures should include the early identification of suitable new sites and seeking to pro-actively work with landowners and developers to bring such sites forward.
The Council must ensure that a new development plan is taken forward without further delay. The continued lack of an up to date development plan is significantly hampering delivery and the regeneration imperative.
Persimmon Homes have an interest in site CFS087: Land between Western Road and Weir Farm Road
Rayleigh, which the Site Appraisal Paper confirms suitable, deliverable and available for residential
development, and are actively seeking additional sites in Rochford to deliver much needed housing and
regeneration in the Borough. Further details of this site, along with plans, are submitted as part of this submission to support its allocation within the Local Plan for development.

Seetec – Introductory Comments
With our head office in the Rochford district, we are one of the UK’s largest employee owned businesses, employing over 2,000 people and committed to building our history of service.
We help people in the UK and Ireland to increase their social and economic stake in society. We do this by providing skills, training and support services that people need to reach and exceed their ambitions, creating positive change for the communities we serve
Our aim has always been to change lives for the better. Founded more than 35 years ago as a small charity, we first taught IT skills to 30 unemployed young people at a former primary school in Hockley. From these humble beginnings, we now help hundreds of thousands of people find work, learn new skills and take ownership over their lives.
We understand the needs of the people we support. As employee owners, we now want to drive further improvements and continue to generate enduring positive outcomes for the people and communities we service.
As a B-Corp organisation we are business committed to social value by reducing inequality, working toward lower levels of poverty, a healthier environment, stronger communities and the creation of high quality jobs with dignity and purpose.
We care passionately about the District, its environment, open spaces, heritage and sustainable living. Our business has made a long term contribution to the District and this response is intended to reflect our on-going ambition to make Rochford district a first class place for health & wellbeing, work, learning and leisure. The choices the Council makes over the next 35 years will be key to this ambition.

Consultation Representations
Our responses and representations to the questions from the above consultation are set our below. We have replied to some specific questions and used cross references where appropriate to avoid duplication.
• Introduction
o
 Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
Agree
 Q4. Do you agree with the strategic priorities and objectives we have identified?
Agree
• Strategy Options
 Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
We prefer taking forward Option 4 Balanced Combination with the following comments, preferences and concerns regarding risks.
In general, the preference is for a ‘selective’ ‘Strategy Option 4’ approach by combining Strategy Option 1 Urban Intensification; Option 2 Urban Extensions and Option 3a Concentrated Growth in the west of Rayleigh. This would need to be in specific sites and it will be easier to quantify for housing targets if we were to identify sites that we would not support.
We would not support Option 3b North of Southend and 3c Focused East of Rochford and the land allocations from Rochford to Hockley in the 2017 Strategic Housing and Employment Land Availability as well as some other sites in Lower Hockley and Rayleigh. These are transport infrastructure and risk related objections whilst there are others that negatively impacting heritage, character and setting.
The specific areas of allocations of concern are listed below:
CFS035 land west of Rochford hall 1.25 hectares
CFS041 Lee valley farm 2.54ha
CfS074 land south of Mount Bovers Lane 14.22ha
Cfs077 land north of Great Wheatley’s Road 7.5ha
CFS084 land south of hall road 7.16
CFS085 land west and north of Hall Road 2.22
CFS087 land between Western Road and Weir Farm Road 3.08
CFS121 land north of A127 38.48
CFS150 land on the north side of Victor Gardens 1.73
EXP12 land adjacent 44 Great Wheatley Road 0.12
These will exacerbate the B1013 ‘rat run’ causing huge congestion and comprised emergency evacuation with the potential risk of:
• global warming repeating ‘1950’s scale flooding’ in South East Essex,
• nuclear contamination (Bradwell) and
• airport / rail disaster.
Any development must be matched by adequate transport solutions. Until this document is available then it is difficult for consultees to make informed representations and the Council to make evidence based decisions. The whole approach is somewhat ‘chicken and egg’. The transport solution should be the first document given the historic challenges and earlier consultation responses. Once this is available, the context of spatial options can be evaluated on sound evidence as community and population safety will be of paramount concern.
Assuming there is no radical bypass, which we would not support anyway given the intrusion into Crouch Valley conservation, solutions must be found to the key rail bridges and Rayleigh Weir underpass. These are high risk pinch points for local population and egress in particular:
Rochford Bridge / Hall Road
Hockley Bridges (Greensward Lane & Church Road)
Rayleigh station (London Road)
A127 Weir underpass
As a minimum, solutions must be found to these bottle-necks - widening the bridge underpasses, flyovers etc. If certain developments were to go ahead, flooding and the increased congestion of Options 3a, 3b and the proposed allocations along B1013 will potentially lock-in and lock-out population from their homes, shops, work and living in safe communities.
• Employment and Jobs
 Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?
Any growth must be contingent on the transport infrastructure comments in this representation, without this future growth is limited. In addition, it is important for quality of living that night flights are stopped and pollution and noise controls are enhanced.
• Green and Blue Infrastructure
 Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
We refer you to our comments and sites outlined at Q6.
• Heritage
 Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?
Remove allocations that threaten the key heritage sites in the District e.g. CFS035, CFS084, CFS085
 Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?
Grade 1 Rochford Hall and setting.
Rochford Conservation Zone
Crouch Valley
• Town Centres and Retail
 Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
As regard Hockley town centre we have previously stated our preference to develop an imaginative town setting that brings Hockley Woods into the town e.g. shop ‘timber’ facades, woodland street furniture etc thus celebrating the setting of Hockley in its ancient woodlands and Spa.
• Transport and Connectivity
• We refer you to our responses under Q6 and Q28

 Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
We refer you to our responses under Q6 and Q28
 Q52. Are there areas where improvements to transport connections are needed?
We refer you to our responses under Q6 and Q28
 Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
We refer you to our responses under Q6 and Q28

• Planning for Complete Communities

Rayleigh
 Q56d. Are there areas that require protecting from development?
CFS77, CFS087 and EXP12
Rochford and Ashingdon
 Q57d. Are there areas that require protecting from development?
CFS035, CFS084, CFS085 (see Q43 response above)
Hockley & Hawkwell
See representations at Q48
 Q58d. Are there areas that require protecting from development?
CFS041, CFS074, CFS150

Re: Rochford District Council, New Local Plan: Spatial Options Consultation Paper 2021
Consultation regarding the proposed Spatial Options identified by Rochford District Council identifying the
range of challenges and opportunities relating the proposed growth within the Rochford District over the
next 20 years.
Essex Police welcome the opportunity from a designing out crime and crime suppression perspective to comment on the Rochford District Councils – New Local Plan: Spatial Options Consultation Paper 2021.
After review of the documentation, the ‘Essex Police – Designing out Crime Office’ (DOCO) would wish to raise the below for further consideration and would welcome further consultation regarding the below observations.
Please note that it wouldn’t be appropriate for Essex Police to make comment on questions that are commercially sensitive or where the question relates to a specialism outside of the Designing out Crime remit.

Q2. Do you agree with our draft vision for Rochford District?
Essex Police value the importance of addressing the natural environment and health and wellbeing within communities and would request embedding within the vision statement, a focus on promoting and designing a safer community. Implementing designing out crime measures will ensure a sustainable community, where crime is designed out, promoting a feeling of safety.
Appreciative of the holistic vision, Essex Police would welcome the embodiment of ‘safe and secure’ concepts within the vision for Rochford and embedded within such Strategic Documentation. Such an inclusion will ensure that safety has been considered within new proposed allocations.

Q4. Do you agree with the strategic priorities and objectives we have identified?
With regard to the specific strategic priorities and objectives, Essex Police have the following comments and observations:
Strategic Objection No. 5:
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 6:
We would recommend seeking accreditation to SBD Homes and application of CPTED principles throughout the design lifecycle.
Strategic Objection No. 9: Please see the response to Question 51 regarding embedding sustainable transport links
Strategic Objection No. 10:
Essex Police would advocate adopting the ‘Safe Roads Approach’ when designing road infrastructure to ensure the safety of all road users.
Strategic Objection No. 11
Consideration is required to ensure the design embeds the appropriate level of permeability with connectivity
Strategic Objection No. 14
We would recommend the completion of a Health Impact
Assessment, (further information can be found within Q8)
Strategic Objection No. 17
The Essex Police DOCOwelcome the inclusion within this Strategic Objection of engaging with the ‘designing out crime’ team to ensure that all ‘new developments and the public realm are well designing and safe environments’.
Strategic Objection No. 18
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 22 Please see the response to Question 43 regarding heritage and the built environment.
The Essex Police DOCO would welcome when designing safe and secure environments adopting Secured by Design (SBD)principles. As the preferred enabler to mitigate crime, Essex Police advocate both applying ‘Crime Prevention through Environmental Design’ (CPTED) principles and seeking the various accreditations incorporated within the applicable SBD schemes.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?

Constructing well designed places, buildings and communities that promote both sustainable
communities and health and wellbeing is an objective that the Essex Police DOCO widely supports; however, it is imperative that they must also be safe, secure, and accessible. This can similarly be evidenced within the Health Impact Assessment, as mitigating the opportunities for crime is not only about reducing and preventing injury and crime, but it is also about building strong, cohesive, vibrant, and participatory communities.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

Secured by Design (SBD) seeks to achieve sustainable reductions in crime through design and other approaches to help communities live in a safer society. Achieving SBD Homes Gold Accreditation will satisfy the security needs assessment requirements within BREEAM, but also address many of the associated security risks.
Academic research has proven that the application of crime prevention and SBD can see up to 75%
reductions in burglary and 25% for Vehicle crime and ASB. There are substantial Carbon cost savings
associated with building new communities to SBD standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of criminal acts. This will ensure that designing out crime and crime reduction is considered throughout, be that residential, businesses and commercial space.
When considering the lifecycle and increasing the lifespan of building materials and security hardware, (such as doors and windows), Essex Police would recommend utilising companies that have achieved Secured by Design (SBD)Police Preferred Specification.
There are substantial Carbon cost savings associated with building new communities to SBD and SBD
Preferred product standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of future criminal acts.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Essex Police DOCO would welcome the potential inclusion for consultation on all proposed Design
Guides / Codes and or Masterplans to embed designing out crime concepts from the initial stages. To supplement this consultation, Essex Police DOCO would strongly recommend local authorities engage with the DOCO to embed designing out crime and CPTED principles throughout.

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
Essex Police DOCO would advocate that across the various Design Guides / Codes and Masterplan’s a
consistent approached is garnered when approaching designing out crime and mitigating any potential security risk. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend the developer considers the foreseeability of crime and maximise on the opportunity to embed CPTED principles, as these crime types can potentially be ‘designed out’ and minimised with due consideration. This will in turn prevent the need for bespoke situational crime prevention measures in the future and promote a sustainable community.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
When designing new homes and community amenities, it is imperative to consider crime as a material consideration. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend developers consider the foreseeability of crime and maximise on the opportunity to design such issues out, as to prevent the need for bespoke situational crime prevention measures in the future.
It is imperative that design specifications of buildings and the surrounding community are risk commensurate (i.e. correlate to the Security Needs Assessment) and it is important that an effective and realistic level of physical security is commensurate with the risk.
Encouraging residents and users of places to feel a sense of ownership and responsibility for their
surroundings can make an important contribution to the safety of a community. This can be facilitated by clarity in where public space ends and where communal, semi-private or private space begins (intermediate space). Uncertainty of ownership can increase the likelihood of crime and ASB going unchallenged. Inclusive of the above, Essex Police actively encourage the following generalised considerations:
• Access and movement – places with well-defined routes, spaces and entrances that provide for convenient movement without compromising security.
• Structure – places that are structured so that different uses do not cause conflict.
• Surveillance – places where all publicly accessible spaces are overlooked.
• Ownership – places that promote a sense of ownership, respect, territorial responsibility, and community.
• Physical Protection – places that include necessary, well-designed security features.
• Management and maintenance – places that are designed with management and maintenance in mind, to discourage crime in the present and future.
Essex Police would recommend all developments seek accreditation to the various Secured by Design (SBD) Guide or at a minimum the SBD principles.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
With regard to future proposals for the design of Gypsy and Traveller Sites, we would recommend
consideration of the following:
• Careful consideration appertaining to the road infrastructure into the proposed sites, as this will not only promote a safe haven for occupants but may also discourage criminal activity.
Appropriate Emergency Service Access (including necessary turning circles) is required to ensure appropriate access onto the sites.
• Road access to the site and the ongoing farm raises concerns over access and egress onto the site for emergency services and safety of the staff. Along that stretch of road what traffic calming measures will be in place, will this be replicated across the development?
• Necessity for detailed border treatments for the site as judicious planting may not be of a robust nature.
• Boundaries delineation between the public and public realm space needs to be clearly defined, with any open spaces displaying features which mitigate any potential unauthorised access.
• Consideration of the ‘Communities and Local Government, Designing Gypsy and Traveller Sites, Good Practice Guide’ when fine tuning the detail across the site.
• Early liaison with the Designing out Crime Team at the appropriate state of the design to ensure ‘CPTED principles’ are embedded within the design.

Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?
Heritage indirectly features within designing out crime in many respects to ensure that any developments within the conservation areas, (containing listed buildings or other features of value), are protected from crime and ASB within those early planning considerations.
Sometimes heritage becomes an afterthought and measures put into place within a building development that may be to the detriment of a heritage asset, for instance an asset that once had good natural surveillance and passage of the public, becomes within an isolated location with little natural surveillance.

Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?

To create environments that are healthy, accessible, and well-designed, there will be a need to reimagine the way that developers and landscapers deliver key service functions that are effective, and positively influence the design of public realm space. It is important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB, thus having an adverse effect on those communities. Careful consideration is required around
desired levels of permeability and access and egress (i.e. wayfinding) to ensure that crime is not generated as a result.
Consideration is requested by developers and designers to adopt the “Safe system approach” when designing local roads, access road and transport links across proposed development. This will take into consideration the various road user groups who wish to access these roads.
We appreciate that it is important to create a sense of place and build communities with the provision of accessible services and facilities that encourage walking and cycling etc. It is also important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB or generate a fear of crime when using that space, thus having an adverse effect on those communities.
With a focus on sustainable travel across the site, consideration needs to be given to the secure external storage facilities and bicycle security, be this within the home environment or within communal bicycle stores.

Re Rochford New Local Plan, Spatial Options Consultation 2021
Topic Paper 8. Heritage.
I wish to object to aspects of the plan, as follows.
Having read the document Topic paper 8, Heritage, and looked at the local spatial options plan, I note that both the Mill Hall area COL07 and the Civic Suite area COL20 are both included in the local plan as future sites for development. (Blue edged and shaded blue on the map)
Both these sites are situated within Rayleigh’s conservation area, and currently not assigned for residential use.
The Mill Hall site COL07 includes a listed building (the historic Windmill) and an environment of historic importance (Rayleigh castle mount). The site currently includes green areas and trees. This very important amenity is Rayleigh’s heritage and as the term implies must be conserved for the people of Rayleigh.
The Civic suite area COL20 faces on to Rayleigh’s grade 2 *listed Parish Church. Development of this site would detract from the local environment, with loss of green space and trees.
Both areas are valued as open spaces with important heritage significance. They are protected by being in the conservation area.

Not only is mill Hall and the surrounding area, I believe a conservation area, but is also an important part of local history..there are already far too many new builds going up in rayleigh and surrounding areas, so enough is enough..please listen to the opinion of local people and stop any redevelopment of this area, otherwise I will consider suing rochford district council for what I believe is probably illegal activity any way.

Rgds

Michael wood

Ps how many councillors who make these decisions actually live in Rayleigh?
Probably hardly any

Re: Rochford District Council New Local Plan: Spatial Options Consultation Paper 2021

Thank you for consulting Historic England on the Council’s New Local Plan: Spatial Options Consultation Paper 2021. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

We welcome the production of this consultation paper, but do not currently have capacity to provide detailed comments, and instead provide the following high-level comments which we hope you will find helpful.

Please note that the absence of a comment on an option or question in this letter does not affect our obligation to provide further advice and comment on specific proposals in the future, particularly where we consider that these would have an adverse effect upon the historic environment.

POTENTIAL SITE ALLOCATIONS

The Plan includes details of all sites that have been promoted for development as part of the new Local Plan. We understand that these sites will undergo further assessment before the Council identifies those sites which it deems suitable for inclusion in the Plan. To assist with this the Council has commissioned a high level heritage assessment of the Call for Sites submissions (Place Services, October 2020) which will ensure that heritage is considered consistently across all sites and heritage assets, and which we commend.

Further assessment of sites

Our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan.

In essence, it is important that you:

1. Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale;

2. Assess the contribution of the site to the significance of heritage assets on or within its vicinity;

3. Identify the potential impacts of development upon the significance of heritage asset including impacts resulting from a changing in setting;

4. Consider how any harm might be removed or reduced, including reasonable alternatives sites;

5. Consider how any enhancements could be achieved and maximised; and

6. Consider and set out the public benefits where harm cannot be removed or reduced

Looking at the above, it can be seen that the Council’s existing heritage assessment only really deals with the first 2/3 steps of the 5-step process and does not comprise a full heritage impact assessment of each of the sites (which the heritage assessments acknowledges). In order to help refine which sites to take forward, we would therefore suggest that Heritage Impact Assessments (HIAs) are undertaken for those which are considered to be contenders, but for which heritage issues have been identified. This should be proportionate (both to the scale of the site and the assets affected). Again, we would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans.

As the Council begins the next stage of assessing sites it will be important to identify those which are inappropriate for development and also to assess the potential capacity of each in the light of any historic environment (and other) factors. It is worth stressing here that mitigation required to make a site acceptable from a historic environment perspective may mean that either, a site cannot actually be developed or the anticipated quantum of development is undeliverable. This is particularly an issue for smaller sites which may find it difficult adapt to the necessary mitigation measures, and this could have consequences for the suitability and achievability of these sites in terms of the Councils’ supply.

Site specific policy criteria informed by further heritage assessment

Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal with the Planning Practice Guidance stating “where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the ‘what, where, when and how’ questions)” (Paragraph: 002 Reference ID: 61-002-20190315 Revision date: 15 03 2019). Conservation of the historic environment is a part of the key overarching environment objective (Paragraph 8c) and Local Plans should set out a positive strategy in this respect (Paragraph 190). To this end, if a site is allocated then the findings of the HIA should inform the site-specific policy including any specific development criteria required. We would also expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the significance of on-site or nearby heritage assets (noting that significance can be harmed by development within the setting of an asset), the need for high quality design and any other factors relevant to the historic environment and the site in question.

FURTHER GUIDANCE

We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your plan preparation process:

The Historic Environment in Local Plan - Good Practice Advice in Planning 1
<https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans/>

The Setting of Heritage Assets 2nd ed. - Good Practice Advice in Planning 3
<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/>

The Historic Environment and Site Allocations and Local Plans - Advice Note 3
<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/>

CONCLUSION

We look forward to engaging with you as these proposals progress over the coming months. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise (either as a result of this consultation or in later versions of the plan/guidance) where we consider that these would have an adverse impact upon the historic environment.

If you have any queries about any of the matters raised above or would like to discuss anything further, please do not hesitate to contact me. I would be grateful if you could confirm receipt of this email.

• Dear Sir/Madam, On your Rochford district web page it states that I could give my comments to this e-mail address. I object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as a future residential development site.
Under Section 71 of the Planning (listed Buildings & Conservation Areas) Act 1990 and other legislation Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation Area. Both sites are surrounded by listed buildings and a Scheduled Ancient Monument in the case of Mill Hall, neither should not be developed for housing. The setting of the listed buildings are also greatly enhanced by the gardens and the landscaped car parks which make a significant contribution to the conservation area, these would be lost if developed for residential use.
Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.
It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).
Under S.40 of the Natural Environment & Rural Communities Act 2006, the local planning authority has a duty, when exercising its functions, to conserve biodiversity. The green areas and trees on both sites greatly contribute to the biodiversity of the area. In particular in this conservation area, which is not only valued for its buildings but for the mature trees and open space owned by the public. The loss of this biodiversity would be unacceptable if these sites were changed to residential use in the next local plan.
The contribution of car parking to the vitality of the town centre is significant and loss of public car parking within COL07 an COL20 would be detrimental to the Rayleigh Town Centre.

RDC/Spatial Consultation 2021 Questions

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
A: Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.
Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included? [Please state reasoning]
A: Mostly, although I do not feel you have included enough information on how you might achieve housing for the hidden homeless or those on low incomes, emergency housing provision, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
A: Yes, as each settlement has its own characteristics and needs.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
A: Don’t know.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
A: Yes. Rayleigh is the largest town in the district but you need to maintain the green boundaries between the surrounding areas.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
A: A combination of 3 and 4.
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. Combining this with option 4 could help with spreading the balance of housing needs, traffic, etc. across the whole of the district and not just in one place.
Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
A: Windfalls should be included in the housing quota.
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
A: Yes: Cultural and Accessibility.
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change? [Please state reasoning]
A: Yes. We need to ensure we have a suitable plan to protect not only our towns and village communities (houses/businesses) but also the natural areas as well. We need adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
A: Yes. I feel all of our coastal areas and areas of special interest, where there is a significant risk of flooding and harm to the environment needs careful consideration. Our ancient woodlands also need to be protected and well managed.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A: Vast swathes of land being used for solar panels or unsightly wind farms should not be allowed. I do not feel we have used the potential of tidal renewable energy themes. We have potential in some areas to explore this without defacing our district. All new homes should be fitted with solar, either on their roof or windows and commercial properties could be encouraged to fit solar panels to their roof.
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at? [Please state reasoning].
A: I believe that we should aim to achieve a higher standard if possible and encourage developers to put forward new ways of achieving this. We are planning for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher!
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
A: Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs (there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape). Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. No wind turbines! They would ruin the landscape.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas? [Please state reasoning]
A: The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and time again out SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
A: They are, as long as they are adhered to.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A: Yes.
➔ Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? [Please state reasoning]
A: You need different design guides/etc as our district is unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
➔ Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
A: You need to ensure that the character and heritage of our settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
A: By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
A: The district has a large number of houses, existing and approved that have 4 or 5 bedrooms. The number of homes available with 2 or 3 bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. We should ensure that our “affordable“ properties are not all flats and that the minimum (or higher) standards are met for gardens/recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living/residential /retirement home. They may want a 1 or 2 bedroomed property, maybe one storey, or low rise apartment that they own freehold. We also need to consider that some of our residents may need residential care and we should be looking at ways to cope with the rising number of elderly and provide accommodation for them also. We desperately need to meet the needs of the hidden homeless. The adult children on low wages that have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. We also need accessible properties for our disabled members of our community, where they are assisted in order to fulfil a normal as possible life. Emergency and social housing also need to be addressed.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
A: Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled (physical, blind, etc.). Smaller, free hold properties for the older generation to enable them to downsize from large family homes. Social housing. Emergency housing.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
A: Easy access re large vehicles to the site and main roads to ensure the residential roads are not blocked by the larger vehicles. Room for some expansion that would not encroach on the surrounding area. Away from residents to reduce disturbance of vehicle movements. Not in an area of interest or recreation where the landscape would be blighted by the appearance of many vehicles. Not all in one area – spread out our quota across the district in order to avoid another Crays Farm scenario.

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
A: The council needs to stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. They can then concentrate on helping those businesses wanting to expand to be able to do so. They should look to working with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. They then need to assist in schemes to train all ages get back into work or upskill.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
A: No. The current employment site allocations on Figure 30 do not provide enough space to meet the District’s employment needs through to 2040. We have around 87,000 people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. We only need to formally protect sites that have a future and a potential to expand or continue effectively. Green belt sites should be assessed separately and decisions made on merit.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
A: Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development. Option 4 could assess existing sites across the district and the options to be able to expand, as well as areas for new sites.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
A: Environmental services - woodland conservation/management. (We need to find funding for this as it is important!) HGV training school.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
A: Better road networks and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
A: Unsure, but I feel there is not enough room for too much expansion ie. add another run way. The council could consider a park and ride park, to divert some traffic away from the residential area, which could create jobs for security services, bus drivers, attendants, cleaners, etc. Expansion of the airport may affect the Grade 1 listed St Laurence and All Saints Church and this needs careful consideration.
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: We all should be doing everything in our power to protect wildlife sites. All wildlife is important and we have been neglecting them, and slowly chipping away at them for years. Wildlife now enter suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. We have a decline in Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews. Ask yourselves: when did you last see a live hedgehog or badger? Most (especially badgers) are usually dead (along with foxes and deer) by the side of our roads. We have removed places that have housed bats and now we do not see them flying around the district in the numbers they did. Designating initial sites is a step in the right direction but we have to do more. It is proven that our mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. We should be looking at creating new sites with every large housing development, and adding them to our protected list in order to improve our district and our own wellbeing. We should no allow private households to take over grass areas and verges (or concreting the verges over for parking and cost savings). These areas, although small are still areas for wildlife (bees and butterflies - also in decline, as well as bugs which feed our birds). We should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. We should be exploring smaller sites that we could enhance, manage and protect in order to give future generations something to look back on and feel proud that we have given them a legacy. Something that we can be proud of.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: Yes. We need to protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
A: On site. You can then assess in real time and sort out any issues you would not have known about off site.
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan? [Please state reasoning]
A: You need to enhance and maintain what we already have by ensuring the necessary links are in place to link as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces (ie in the car park – a small toilet block and hand washing facilities). Obtaining funding from large (and medium) developments for enhancement of existing areas as well as providing new spaces and facilities is a step in the right direction.
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
A: They are a step in the right direction but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
A: Enhancing the areas we have and ensuring developers include green space/recreational facility areas within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are accessible for the disabled.

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan? [Please state reasoning]
A: Ensuring that funding for existing facilities comes from new developments and making sure that these facilities are built during the time of the development (not like the London Road/Rawreth Lane development where a site was “provided” for healthcare but has not been built). Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A: A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
A: Rayleigh is overcrowded. It has a road network no longer fit for purpose. The schools are almost full. It is difficult to obtain a GP or dental appointment. There is little to no disabled play areas/equipment. There is always issues with waste collections, drain & road cleaning and verge trimming. The council does not have the staff to deal with all these issues. The council needs to either build another waste recycling site (as the one in Castle road is no longer capable of expanding and meeting the needs of its ever growing population) or develop a better waste collection program which allows extra waste to be collected next to bins. It also needs to find a site to address/install commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
A: Improve what we already have. The tennis courts on Fairview Park need improvement. Safeguard our open spaces to ensure we have wildlife and recreation. Develop different types of sporting facilities – not just football pitches. There is a need for a larger skateboard park and BMX track. We need to offer free recreation for our teenagers.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: The development of 3G pitches seems to be the trendy thing to do but they are plastic grass at the end of the day and we should be looking at ways to reduce our plastic use. If there is an area that already exists that is in a poor start of repair then it may be an option – especially if the “grass” is made from recyclables, but we should be thinking outside the box and not covering our parks with it.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A: A new development would be able to deliver this in their plans or fund improvements for existing facilities.
Q42. Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
A: The sites will be specific in each parish. You need to protect all of these recreational spaces and improve if necessary as once lost to development, they can ever come back.
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan? [Please state reasoning]
A: You need to reassess your policies on planning regarding alterations made to the buildings on your list, especially in our conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work (if any) needs to be sympathetic to the area and you should be able to request amendments to frontage, even if they have had it up for some time. Shop fronts are huge areas of uninteresting glass with garish colours. Signage and advertising (‘A’ board’s litter our pavements without challenge and large barriers are erected onto the pavements – totally out of character with a conservation area in a heritage town. Stick to your policies.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
A: Unsure although we need to stop taking areas of our precious woodland to make way for housing.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
A: Don’t know. Mill Hall? Over 50 years old. Cultural centre in a conservation area. Needs massive investment and management. A new survey needs to be taken to ascertain whether there are any other areas that should be considered. There are many buildings along the High Road into Rayleigh (but not in the conservation area) which should be considered.
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
A: You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme (you could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their business). You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows (ie. photos of the old towns or useful information) to make them more attractive.
You will need good access links with an excellent road and cycle network and reliable public transport that links effectively from all the villages to all the towns.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
A: Yes.
Q48. With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
A: Yes
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
A: Yes. We do not want rows of hairdresser or rows of takeaways etc. as this would eventually kill off our high streets. We need to have a balance of outlets. You would lose the vibrancy you are hoping to achieve if you allowed this. You should also consider restricting use to giant chains as these tend to be the first to go in a crisis and make high streets lose their individuality by them all looking the same.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
A: Unfortunately, some of our smaller retail areas have been sold off and housing development has been allowed (eg. Rayleigh - rear of Marks & Spencer and Dairy Crest plus Lancaster Road [builders’ yard]). In a new development there would be scope to add a small/medium/large precinct of retail etc. depending on the development size.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan? [Please state reasoning]
A: The council needs to address the “No development before infrastructure” mantra! Too many houses are being built without adequate road networks in place (including walking and cycling routes). A new road could be built from the A1245 to Hullbridge, limiting the traffic on Rawreth Lane. More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access although I am unsure how that can be achieved. New developments should put in cycle paths and walkways and they could be made to link up with existing paths (which need updating and attention).
Q52. Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
A: More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [Walking, cycling, rail, bus, road etc.]
A: A new road from A1245 to Hullbridge is needed as Watery Lane is too narrow and winding, and is closed on a regular basis due to flooding. More (smaller) buses to link our towns and villages. Trams, although they seem a good idea, would cause congestion on our narrow roads and be unsustainable. Designated cycling paths (not on the roads or pavements) adjacent to our road networks would help improve traffic flow and these would need to be linked to be efficient.
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
A: Yes, but if they are to be affordable only, then they should be offered to local residents first and not anyone from afar who wants a cheap house or for those with a buy to let mortgage.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
A: Improve public transport.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
A: Yes but you also need to include a reduced volume of traffic and air pollution. The High Street is usually grid locked and this causes dangerous pollution for our pedestrians/shoppers/residents. An active Police presence.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Access and increased congestion is going to be an issue with a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town we will create an overcrowded impacting on the developments already there and an urban sprawl effect. CFS 121 has potential for a new woodland area which could soak up some of the carbon emissions from the A127 traffic.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: We should be restricting any further large developments in Rayleigh and need to assess the impact of the current developments first.
Q56d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: CSF027 – The access road (Bull Lane) is a known rat run and is extremely busy. Any further traffic, which will also compete with large agricultural vehicles, could be a danger to the residents already there. Bull Lane near this point has also been flooded several times recently. CFS023 – Access to this road is via Wellington Road. It can be extremely difficult, especially at peak times (non-pandemic) to access to and from Hockley Road. Adding a large development here will have an adverse impact on existing residents and car users alike. Also, if these 2 developments are linked to Albert Road, the installation of a through road to Bull Lane will cause issues in parking, access and wellbeing as the road would become another rat run!
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
The green space north of CFS121 could be linked by a new bridge over the railway and create a new habitat for wildlife, with meadows and woodlands, walks and a lake/pond. A car park with facilities could be created and a small retail space could be offered for snacks etc.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
A: I feel CFS261 would cause great harm to the area, with a potential of over 4,000 houses on the site. The road network is not sufficient to cope with half that amount of dwellings and new schools would need to be built.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q57d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold some significance, especially to those who use them for recreation, and have community value. These should be protected.

Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know
Q58d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: As Hockley Woods is the largest remaining wild woodland in the country you should be doing EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status.
Q58e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of the Wakerings and Barling?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Any development needs to be sympathetic of the area.
Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: Don’t know.
Q60a. Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes, although you need to address the road networks as well as those you have suggested. A new link road from A1245 to Hullbridge, adjacent to Watery Lane would serve the increased population with an improved access route and divert traffic away from other areas.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hullbridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Some of the sites have potential to include a mix of shops, leisure, recreation, offices and housing but a study needs to be made to assess the impact of the current development
Q60c. Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q60d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Anything too close to the river due to flood risk.
Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q61a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]
A: Yes. A small amount of housing can be sustainable there as long as the community feel it is needed.
Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Canewdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Opportunities for mixed retail, commercial and housing could be achieved with some sympathetic development in this area.

Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q61e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes.
Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Any development needs to be sensitive and sympathetic to this small village.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q62d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rawreth?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Yes. Those that border the main roads as this makes easy access.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Those that change the dynamics of the village and those areas that border Wickford. There needs to be a significate amount of green belt land left to separate the 2 areas to prevent urban sprawl.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
A: I think the 30 houses is the maximum you should build to keep this hamlet special. Maybe less. The community should be consulted for their requirements.
Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Paglesham?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: The 30 proposed houses should reflect the history of the area and should be modest in size and scale. These does not seem to be scope for any other building project with exception to open space. Any development should be sympathetic to the design and scale of the areas history.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Those proposed seem appropriate subject to local knowledge and support.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: No building anywhere where it is liable to flood. No building near the waterfront in order to protect its charm and history.
Q64e. Do you agree that the local green spaces shown on Figure 52 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes. These areas should remain low key but have better access to services.
Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know, but mass development should not go ahead. The potential of building thousands of houses, retail etc would be devastating. If any form of development was to go ahead then this should be in the way of a nature reserve/woodland etc.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Most of the area unless it is the creation of new woodland, ponds, meadows, etc.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
A: At this time – yes, but I feel they should have some consideration in the future in order to protect them.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
A: Yes. Nothing missing I can think of.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
A: Survey and listen to the residents to see where they would like to go next. See if they require anything specific (travel links, facilities, affordable housing, etc.)

I wish to object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the local plan as a future residential development site.

Both sites are surrounded by listed buildings and Mill Hall by a Scheduled Ancient Monument. The setting of the listed buildings is enhanced by the gardens and landscaped car parks, making significant contribution to the conservation area and would be lost if developed for residential use.
Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation area, under section 71 of the Planning (listed Buildings and Conservation Areas) Act 1990 and other legislation.

The contribution of public car parking within COL07 and COL20 is significant to the town centre’s vitality and it would be detrimental to the town centre if it was lost due to development.

The local planning authority has a duty to conserve biodiversity when exercising its functions under S.40 of the Natural Environment and Rural Communities Act 2006.
It would be unacceptable if the mature trees and open space owned by the public in sites COL07 and Col20 were lost to residential use in the next local plan. The green areas and trees are greatly valued and contribute to the biodiversity of the area.

As Rochford Council has a duty to contribute towards achieving sustainable development under S.39 Planning and Compulsory Purchase Act 2004, the Planning and Compulsory Purchase Act 2004 and other legislation and guidance it is important to invest into present buildings to make them more sustainable.
The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. Investment should be made into the current buildings to make them more sustainable.